Allocations & Substantial Economic Effect

Topics

July 1, 2017

Temporary disguised-sale regulations raise concerns

Should the IRS consider recognizing a contributing
partner’s economic risk of loss when the regulations are finalized?

December 1, 2016

IRS Rules Govern Disguised Sales and Allocations of Partnership Liabilities

The regulations address disguised sales of property by or to a partnership and allocations of excess nonrecourse liabilities to partners.

October 4, 2016

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.

April 1, 2010

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.

February 1, 2010

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.