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TREAS/IRS | RIN: 1545-BL51 | Publication ID: Fall 2024 |
Title: Section 267--Transactions Between Related Persons and Partnerships | |
Abstract:
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will address whether the rules in the aforementioned section 267 regulations relating to partnerships have been superseded by statute.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. |
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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 |
CFR Citation: 26 CFR 1.267(a)-1 26 CFR 1.267(b)-1 26 CFR 1.707-1 26 CFR 1.707-9 | |
Legal Authority: 26 U.S.C. 7805 26 U.S.C. 267 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-131756-11 (NPRM) Drafter attorney: Livia Piccolo (202) 317-7007 Reviewer attorney: Roy Hirschhorn (202) 317-7007 Treasury attorney: Sarah Haradon (202) 622-6111 and Roger F. Pillow (202) 744-5114 CC:ITA | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Federalism: No | |
Included in the Regulatory Plan: No | |
RIN Information URL: https://www.federalregister.gov/documents/2023/11/27/2023-25715/transactions-between-related-persons-and-partnerships | Public Comment URL: https://www.regulations.gov/document/IRS-2023-0057- |
RIN Data Printed in the FR: No | |
Agency Contact: Livia M. Piccolo Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW, Washington, DC 20224 Phone:202 317-7007 Fax:855 576-2340 Email: livia.m.piccolo@irscounsel.treas.gov |