The Tax Court found a regulation invalid to the extent it holds the period open for the IRS to issue a final partnership adjustment longer than the statutory 270 days after a partnership has submitted ...
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 ...
On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis ...
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