New Partnership Rules 'Upgrade' Existing Guidance, Practitioners Say

For over 50 years, Bloomberg Tax’s renowned flagship daily news service, Daily Tax Report® has helped leading practitioners and policymakers stay on the cutting edge of taxation and...

Nov. 4 —  New IRS guidance on how partners should measure an interest in a partnership is a big improvement over the existing regulations, although some issues remain, practitioners told Bloomberg BNA.

The proposed rules are “a significant upgrade, ”Aaron Nocjar, a partner with Steptoe & Johnson LLP, said Nov. 3. The Internal Revenue Service and Treasury Department should be commended for rules that offer flexibility and eliminate some traps for partnerships under the old guidance, he added.

“We were hoping they would follow a hypothetical sales approach and our calls were answered,” Todd McArthur, a principal in PricewaterhouseCoopers LLP's Mergers & Acquisitions Tax group, said Nov. 4. “The rules are a lot better than what we have now.”

Request Daily Tax Report