June 18, 2018

 

In REG-131186-17, the IRS announced that it is withdrawing the temporary regulations issued in T.D. 9788, which addressed the allocation of partnership liabilities for disguised-sale purposes (the Sec. 707 temporary regulations) and proposing to reinstate the prior regulations under Regs. Sec. 1.707-5(a)(2). The IRS, however, announced that it is keeping the regulations on bottom-dollar guarantees that were also issued as part of T.D. 9788.