Proposed regulations - Disguised sales of property to or by a partnership under section 707 

January 29: The Treasury Department and IRS today released for publication in the Federal Register proposed regulations (REG-119305-11) under section 707 of the Code providing guidance on disguised sales of property to or by a partnership and under section 752 relating to the treatment of partnership liabilities.

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


Read the proposed regulations [PDF 279 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 Thursday, January 30, 2014.


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




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