Initial analysis - Proposed regulations on allocation of recourse, nonrecourse liabilities among partners under section 752 and disguised sales of property to partnership under section 707 

January 29:  The Treasury Department and IRS today released for publication in the Federal Register a set of long-awaited proposed regulations (REG-119305-11) providing guidance on the allocation of recourse and nonrecourse partnership liabilities among the partners under section 752 and on disguised sales of property to or by a partnership under section 707(a)(2)(B).

The proposed regulations address certain deficiencies and technical ambiguities in the current section 707 regulations and certain issues in determining partners’ shares of liabilities under section 752.

Read a report of KPMG’s initial analysis [PDF 85 KB] of today’s proposed regulations.

©2014 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.

The KPMG logo and name are trademarks of KPMG International.

KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.

The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

Direct comments, including requests for subscriptions, to
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.

Share this

Share this


Current and future KPMG clients may subscribe to TaxNewsFlash email alerts.

Email your contact information.

Other TaxNewsFlash publications

TaxNewsFlash-United States by year