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TREAS/IRS | RIN: 1545-BO44 | Publication ID: Fall 2023 |
Title: Partnership Transactions Involving Equity Interests of a Partner | |
Abstract:
These proposed regulations will modify one or more definitions in the regulations under section 337(d). Those regulations set forth rules to prevent a corporate partner from avoiding corporate-level gain through transactions with a partnership involving equity interests of the partner. Those regulations apply when a corporate partner acquires or increases its interest in its own stock held by a partnership in exchange for appreciated property, and also addresses partnership distributions of corporate partner stock to the corporate partner. |
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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 |
CFR Citation: 26 CFR 1.337(d)-3 | |
Legal Authority: 26 U.S.C. 7805 26 U.S.C. 337(d) |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-135671-17 (Final) Drafter attorney: Kevin Babitz (202) 317-5046 Reviewer attorney: Richard Probst (202) 317-5044 Treasury attorney: Sarah Haradon (202) 622-0322 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: Kevin I. Babitz General Attorney (Tax) Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 5107, Washington, DC 20224 Phone:202 317-5279 Fax:202 317-6730 Email: kevin.i.babitz@irscounsel.treas.gov |