Internal Revenue Service June 12, 2015 – Federal Register Recent Federal Regulation Documents
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Partnership Transactions Involving Equity Interests of a Partner
This document contains final and temporary regulations that prevent a corporate partner from avoiding corporate-level gain through transactions with a partnership involving equity interests of the partner. These regulations affect partnerships and their partners. The text of these temporary regulations serves as the text of proposed regulations (REG-149518-03) published in the Proposed Rules section in this issue of the Federal Register.
Aggregation of Basis for Partnership Distributions Involving Equity Interests of a Partner
This document contains proposed regulations that would allow consolidated group members that are partners in the same partnership to aggregate their bases in stock distributed by the partnership for the purpose of limiting the application of rules that might otherwise cause basis reduction or gain recognition. The proposed regulations would also require certain corporations that engage in gain elimination transactions to reduce the basis of corporate assets or to recognize gain. The proposed regulations affect partnerships and their partners.
Partnership Transactions Involving Equity Interests of a Partner
In the Rules and Regulations section of this issue of the Federal Register, the IRS and the Treasury Department are issuing temporary regulations that prevent a corporate partner from using a partnership to avoid corporate level gain required to be recognized. These regulations affect partnerships and their partners. The text of the temporary regulations in this issue of the Federal Register also serves as the text of these proposed regulations.
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