New Treasury Regulations Curtail Planning Opportunities for Partnership Structures

October 25, 2016

The U.S. Treasury Department and the Internal Revenue Service issued final and temporary regulations (the “2016 Regulations”) on October 5, 2016 addressing the partnership disguised sale and debt allocation rules. The 2016 Regulations limit or, in some cases, eliminate taxpayers’ ability to achieve tax deferral in certain partnership structures where deferral previously was available.

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