Proposed regulations - Determining a partner’s economic risk of loss for a partnership liability 

December 13:  The Treasury Department and IRS today released for publication in the Federal Register proposed regulations (REG-136984-12) providing guidance as to when and to what extent a partner is treated as bearing the economic risk of loss for a partnership liability when multiple partners bear the economic risk of loss for the same partnership liability—i.e., an overlapping economic risk of loss.

Also, the proposed regulations provide guidance when a partner has a payment obligation with respect to a liability or makes a nonrecourse loan to the partnership (and no other partner bears the economic risk of loss for that liability) and that partner is related to another partner in the partnership.


Read the proposed regulations [PDF 115 KB]


Written or electronic comments and request for a public hearing must be received by a date that is 90 days after these proposed regulations are published in the Federal Register, on Monday, December 16, 2013.


Additional discussion and initial analysis of these proposed regulations will be provided shortly by KPMG.




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