In the case of a sale or exchange of an interest in a partnership, liabilities shall be treated in the same manner as liabilities in connection with the sale or ...

Under this section, an increase in a partner's share of liabilities is generally treated as a contribution of money by the partner to the partnership, and a ...

Internal Revenue Code Section 752. Treatment of certain liabilities. (a) Increase in partner's liabilities. Any increase in a partner's share of the ...

Section 752(b) provides that any decrease in a partner's share of the liabilities of a partnership, or any decrease in a partner's individual liabilities by ...

If one or more partners bears the economic risk of loss as to part, but not all, of a partnership liability represented by a single contractual obligation, that ...

Dec 16, 2013 · The proposed regulations provide that the related partner exception only applies when a partner bears the economic risk of loss for a liability ...

The 752 Regulations are used in determining a partner's economic risk of loss for partnership debt. These regulations apply a test Denver Tax Lawyer ...

Dec 20, 2019 · Recent final regulations under IRC Section 752 institute a new rule for allocating partnership recourse liabilities.

Apr 30, 2014 · Proposed regulations on partnership recourse liabilities and special rules for related persons address issues that are either ambiguous or ...