IRS Issues Proposed Rule On Partnership Recourse Liability

Law360, New York (December 13, 2013, 3:43 PM EST) -- The Internal Revenue Service released proposed regulations Friday that address when and how one partner should bear the risk of loss for a partnership liability.

Section 752 of the Internal Revenue Code says a partner's share of a recourse liability, which is a liability that the partner is personally responsible for, is equal to the partner's risk of loss for the liability. But there has been uncertainty over how partnership liabilities should be shared when multiple partners bear a risk of loss for the same liability,...
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