IRS Issues Final Rules for Partnership Recourse Liabilities (1)

Nov. 29, 2024, 9:08 PM UTCUpdated: Nov. 29, 2024, 9:02 PM UTC

The IRS published regulations (TD 10014) Friday detailing recourse partnership liabilities and related party rules.

Recourse liabilities are a type of debt that holds specific partners personally liable if the partnership defaults on the loan. In other words, partners bear the “economic risk of loss” when they take on a recourse debt.

The final rule under Section 752 adopts the proposed regulation (RIN: 1545-BL21) with certain modifications. The agency concluded that there were no changes since the proposal was released 11 years ago in 2013, thus another proposed regulation would further delay the final rule.

The ...

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