Update rules for the application of section 267 to partnership transactions. Specifically, questions exist as to the continued applicability of the current regulations under section 1.267(b)-1(b) and question 2 and 3 of section 1.267(a)-2(T)(c) due to statutory changes to sections 267 and 707(b). The regulations will address whether the rules in the aforementioned section 267 regulations relating to partnerships have been superseded by statute. The IRS and Treasury solicited and received public comments on the proposed rule and are reviewing and considering those comments, to include those submitted after the comment period closed.