Internal Revenue Service November 23, 2016 – Federal Register Recent Federal Regulation Documents

Fractions Rule
Document Number: 2016-27105
Type: Proposed Rule
Date: 2016-11-23
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations relating to the application of section 514(c)(9)(E) of the Internal Revenue Code (Code) to partnerships that hold debt-financed real property and have one or more (but not all) qualified tax-exempt organization partners within the meaning of section 514(c)(9)(C). The proposed regulations amend the current regulations under section 514(c)(9)(E) to allow certain allocations resulting from specified common business practices to comply with the rules under section 514(c)(9)(E). These regulations affect partnerships with qualified tax-exempt organization partners and their partners.