IRS: NYSBA Tax Section Submits Comments on Termination of Partnership Rules Following TCJA (IRC §708)

New York State Bar Association Tax Section submits report to the Treasury and IRS regarding the application of tax code Section 708(b)(1), as added by the 2017 TCJA, Pub. L. No. 115-97. The report notes that before the 2017 TCJA, a partnership would terminate if a transaction fell within the boundaries of the technical termination provision of pre-2017 TCJA Section 708(b)(1)(B), making it easier to ensure a termination for tax purposes. Under current law, however, terminations are governed under Section 708(b)(1) solely, making taxpayers reconsider the tax treatment of certain transactions. [NYSBA Tax Section Report ...