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TREAS/IRS | RIN: 1545-BH89 | Publication ID: Fall 2019 |
Title: Treatment of Grantor of an Option on a Partnership Interest | |
Abstract:
The regulations include partnership interests in the definition of "securities" for purposes of section 1234(b), and also expand the characterization measurement events to include certain transfers of interest in the issuing partnership and other look-through entities. |
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Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Final Rule Stage |
Major: No | Unfunded Mandates: No |
EO 13771 Designation: Other | |
CFR Citation: 26 CFR 1 | |
Legal Authority: 26 U.S.C. 7805 26 U.S.C. 1234 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-106918-08 Drafter attorney: Anthony J. McQuillen (202) 317-5027 Reviewer attorney: Joy Spies (202) 317-6850 Treasury attorney: Karl Walli (202) 622-5721 CC:PSI | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Small Entities Affected: No | Federalism: No |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Anthony J. McQuillen Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 5004, Washington, DC 20224 Phone:202 317-5027 Fax:855 591-7864 Email: anthony.j.mcquillen@irscounsel.treas.gov |