TaxationEzra Dyckman and Daniel Stahl, New York Law Journal
New Regulations on Debt Share for 'Disguised Sales'
In their Taxation column, Ezra Dyckman and Daniel Stahl discuss the new regulations issued by the Treasury Department October 2016 that modify a number of the partnership debt allocation rules and write how the new regulations have taken a "drastic approach, with respect to determining a partner's share of partnership liabilities for purposes of the "disguised sale" rules—and in a surprising twist cause some partnership liabilities to not be included in any partner's share."
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