The U.S. Treasury Department and IRS today released for publication in the Federal Register the following sets of regulations (T.D. 9833) that affect partnerships and their partners:
The purpose of this report is to provide text of the final regulations [PDF 241 KB] (14 pages) that are applicable on or after June 12, 2015.
Read a preliminary report about the 2015 regulations in TaxNewsFlash [PDF 93 KB]
After considering the one comment letter received in response to the 2015 regulations, today's release adopts as final regulations the rules set forth in the 2015 regulations under section 337(d) (with only minor, non-substantive clarifications in response to the commenter’s request for additional certainty regarding certain collateral effects) and section 732(f) (without any change).
The Treasury Department and the IRS are considering publishing a new notice of proposed rulemaking that would propose more substantive amendments to the final regulations under section 337(d) and to allow for additional public comment with respect to these more substantive proposals in response to the comment letter, to further reflection by the Treasury Department and IRS, and to concerns raised by practitioners.
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