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TREAS/IRS | RIN: 1545-BL51 | Publication ID: Fall 2023 |
Title: Section 267--Transactions Between Related Persons and Partnerships | |
Abstract:
Update rules for the application of section 267 to partnership transactions. Specifically, questions exist as to the continued applicability of the current regulations under section 1.267(b)-1(b) and question 2 and 3 of section 1.267(a)-2(T)(c) due to statutory changes to sections 267 and 707(b). The regulations will address whether the rules in the aforementioned section 267 regulations relating to partnerships have been superseded by statute. |
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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: Proposed Rule Stage |
Major: No | Unfunded Mandates: No |
CFR Citation: Not Yet Determined (To search for a specific CFR, visit the Code of Federal Regulations.) | |
Legal Authority: 26 U.S.C. 7805 26 U.S.C. 267 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-131756-11 (NPRM) Drafter attorney: Livia Piccolo (202) 317-7007 Reviewer attorney: Roy Hirschhorn (202) 317-7007 Treasury attorney: Sarah Harodon (202) 527-2032 CC:ITA | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Federalism: No | |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Livia M. Piccolo Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW, Washington, DC 20224 Phone:202 317-7007 Fax:855 576-2340 Email: livia.m.piccolo@irscounsel.treas.gov |