The IRS proposed new rules Friday governing restrictions on tax benefits for deals done between partnerships and related persons, removing and amending rules dating back to the 1950s to align guidance with laws Congress passed decades ago.
The proposed regulations (RIN 1545-BI49, REG-131756-11) would amend tax code sections related to prohibitions on certain loss claims, gain recharacterization, and the matching rule to better reflect Congress’s intention that these be applied at the partnership level rather than the partner level.
In general, partnerships can’t claim losses on deals done with related persons, as defined in the tax code, though ...
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