IRS Considers Project to Address ‘Stuffing’ Allocations, Official Says

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Tax officials are considering adding to the IRS business plan a project to revamp regulations under Treasury Regulations Section 1.704-3(e)(3) to take into account the current structural complexity of hedge funds and other investment partnerships, a Treasury official says. Speaking at a Practising Law Institute seminar on tax planning for partnerships and other strategic alliances, Robert Crnkovich, senior counsel in the Office of the Tax Legislative Counsel, says officials are weighing the possibility of changes that would better reflect today's business realities.