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| TREAS/IRS | RIN: 1545-BO44 | Publication ID: Spring 2025 |
| Title: Partnership Transactions Involving Equity Interests of a Partner | |
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Abstract:
These proposed regulations will modify one or more definitions in the regulations under section 337(d). Those regulations set forth rules to prevent a corporate partner from avoiding corporate-level gain through transactions with a partnership involving equity interests of the partner. Those regulations apply when a corporate partner acquires or increases its interest in its own stock held by a partnership in exchange for appreciated property, and also addresses partnership distributions of corporate partner stock to the corporate partner. |
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| Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
| RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Final Rule Stage |
| Major: No | Unfunded Mandates: No |
| EO 14192 Designation: Not subject to, not significant | |
| CFR Citation: 26 CFR 1.337(d)-3 | |
| Legal Authority: 26 U.S.C. 7805 26 U.S.C. 337(d) | |
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Legal Deadline:
None |
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Timetable:
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| Additional Information: REG-135671-17 (Final) Drafter attorney: Cameron Williamson (202) 317-6684 Reviewer attorney: Richard Probst (202) 317-5044 Treasury attorney:Drew Tidwell (202) 890-7687 CC:PT&E | |
| Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
| Small Entities Affected: No | Federalism: No |
| Included in the Regulatory Plan: No | |
| RIN Data Printed in the FR: No | |
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Agency Contact: Cameron Williamson General Attorney (Tax) Department of the Treasury Internal Revenue Service 1111 Constitution Avenue, NW, Room 5008, Washington, DC 20224 Phone:202 317-6684 Fax:855 591-7865 Email: cameron.t.williamson@irscounsel.treas.gov |
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