The regulations address disguised sales of property by or to a partnership and allocations of excess nonrecourse liabilities to partners.
Allocations & Substantial Economic Effect
Disguised-Sale and Partnership Liability Allocation Rules Issued
The IRS issued three sets of regulations addressing issues of disguised sales of property by or to a partnership and allocations of excess nonrecourse liabilities to partners.
Careful Analysis Required for Potential Regs. Sec. 1.752-7 Liabilities
Regs. Sec. 1.752-7 defines what constitutes a 1.752-7 liability, how these liabilities are treated when assumed by the partnership or another partner, and the impact of a later sale (or redemption) of a partnership interest by the partner that contributed the debt to the partnership.
Current Developments in Partners and Partnerships
This article reviews and analyzes recent rulings and decisions involving partnerships. The discussion covers developments in partnership formation, debt and income allocations, distributions, passive activity losses, and basis adjustments.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.