Tax News

CCH (cch.taxgroup.com) reports:

  The Treasury Department and the IRS have withdrawn proposed regulations relating to the treatment of transactions between a partnership and its partners as disguised sales of partnership interests between the partners under Code Sec. 707(a)(2)( (NPRM REG-149519-03). The proposed regulations sought to amend the existing regulations by adding rules for disguised sales of partnership interests and revising the rules relating to disguised sales of property. The Treasury Department and IRS decided to withdraw the proposed regulations after considering comments from interested parties, but will continue to study this area and may issue future guidance. Until new guidance is issued, any determination of whether transfers between a partner or partners and a partnership is a transfer of a partnership interest will be based on the statutory language, guidance provided in legislative history, and case law.

Withdrawal of Notice of Proposed Rulemaking, NPRM REG-149519-03, 2009FED ¶49,414

Other References:

 
Code Sec. 707

  CCH Reference - 2009FED ¶25,180C

  CCH Reference - 2009FED ¶25,181BC

  CCH Reference - 2009FED ¶25,181DC

  CCH Reference - 2009FED ¶25,181EC

  CCH Reference - 2009FED ¶25,181FC

  CCH Reference - 2009FED ¶25,181GC

  CCH Reference - 2009FED ¶25,181HC

 
Code Sec. 752

  CCH Reference - 2009FED ¶25,524C

  Tax Research Consultant

  CCH Reference - TRC PART: 27,058.05
CCH Reference - TRC PART: 27,058.15
CCH Reference - TRC PART: 27,058.25