IRS T.D.: Allocating Partnership Liabilities for Disguised Sale Purposes (IRC §707)

Regulations regarding allocation of partnership nonrecourse and recourse liabilities in disguised sales replace temporary regulations, the IRS stated in final regulations released October 4. The temporary regulations were included in a report responding to the Executive Order to identify regulations that imposed an undue burden. The final regulations apply to any transaction with respect to which all transfers occur on or after October 4, 2019, the date that the tax code Section 707 temporary regulations expire. The final regulations continue to provide that partnerships and their partners may apply the regulations to any transaction with respect to which all transfers ...