Washington tax watch: Treasury revises liability allocation rules
Article Abstract:
The Department of the Treasury has revised Section 752 of regulations concerning liability allocation in partnerships. The first notice of proposed rulemaking issued simplifies and revises current regulations. The second notice adopts temporary regulations amending effective dates, giving taxpayers more leeway in determining which regulations will cover partnership liabilities. Major revisions in the following rules are taken up: anti-abuse rules, interest guarantees, pledged property, de minimis rule and residual nonrecourse debt. The Proposed and Temporary Regulations' effective dates are also discussed.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1992
User Contributions:
Comment about this article or add new information about this topic:
Partnership classification: recent developments
Article Abstract:
The IRS published two revenue procedures which provide classification guidelines for an organization to be considered a partnership. Revenue procedure 92-33 regulates the free transferability of interests for partnerships which limit transfers exceeding 20% of total interests. Revenue procedure 92-35 sets conditions for a limited partnership's continuity of life. The new regulations amend revenue procedure 89-12, which presents conditions needed for an organization to be considered for partnership taxation.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1992
User Contributions:
Comment about this article or add new information about this topic:
Proposed regulations on basis allocation under subchapter K provide needed guidance
Article Abstract:
The United States Department of Treasury's proposed regulations regarding the exchange or sale of partnership interests are reviewed and issues are examined.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1998
User Contributions:
Comment about this article or add new information about this topic:
- Abstracts: It's what's beyond the figures that really counts. Accountability and acquisitions. The big decision: whether or not to float your company
- Abstracts: Dealing with reality: a lesson for the City. Prize-winning problem solver. Enigma and variations
- Abstracts: Counterpoint. Counterpoint: smart uses for dumb questions
- Abstracts: Making a fair return. Dealing in discipline. Rising to the new Capital challenge
- Abstracts: Partnership return did not affect partner's statute of limitations. Statute of limitations is affirmative defense in partnership proceeding