On December 2, 2024, the Department of Treasury published final regulations (Final Regulations) governing the allocation of recourse liabilities of a partnership among its partners under Section 752 ...

Section 752 and its accompanying regulations require a partnership to allocate its liabilities among its partners, generally resulting in an increase to a partner’s basis in the partnership interest.

On Dec. 2, 2024, the Treasury Department issued final regulations providing more detail on how a partnership’s recourse liabilities must be allocated and in some cases changing the result under ...

A partner’s basis includes the partner’s share of partnership liabilities. 1 An economic risk of loss analysis is used to determine which liabilities are included in a partner’s adjusted basis. A ...

Special rules apply to the allocation of losses and deductions attributable to nonrecourse obligations after 1991. If, however, the partnership agreement has not been substantially modified after 1991 ...

In tax controversy and litigation matters, sometimes procedure trumps the merits. The statute of limitations is a great example. Even if the taxpayer made a mistake on a prior year return, the IRS ...

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