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.
<p>© 2018 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.KPMG International Cooperative (“KPMG International”) is a Swiss entity.</p> <p>Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.<br> </p>
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. 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.