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Disguised-Sale and Partnership Liability Allocation Rules Issued

The Internal Revenue Service issued three sets of regulations last week that address issues of disguised sales of property by or to a partnership and allocations of excess nonrecourse liabilities to partners.  Alistair Nevius, The Tax Adviser’s editor-in-chief, explains these regulations. To read the full article in The Tax Adviser, click: Disguised-Sale and Partnership Liability Allocation Rules Issued. ...

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Chief Counsel Advice Tackles Sec. 752’s Impact on Partnership COD Income

Determining Whether Debt is Recourse or Nonrecourse When a partnership has a debt that is forgiven, its characterization as recourse or nonrecourse can make a big difference in its tax treatment, including being eligible to be excluded under Sec. 108, as this article explains.  Mark Cook, partner with SingerLewak LLP, discusses how Sec. 752 should be interpreted under CCA 201525010. To read the full article ...

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