IRS Close to Reproposing Noncompensatory Partnership Options Rules

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IRS is on the verge of reproposing rules on noncompensatory partnership options, dealing with nonrecognition of gain to both the partnership and the option holder at exercise, says IRS Associate Chief Counsel Curtis Wilson. The original proposed rules met with considerable opposition and were issued so long ago that the final rules would have to be significantly different when they came out, leading the IRS to conclude that new proposed rules should be issued, attorneys familiar with them tell BNA.