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Treatment of Disregarded Entities Under Section 752

tax-irs · IRS · Rule · Published 2006-10-11 · Effective 2006-10-11 · 71 FR 59669

Document

Document number
E6-16719
Federal Register citation
71 FR 59669
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2006-10-11
Effective date
2006-10-11
Treasury docket
TD 9289

Abstract

This document contains final regulations under section 752 for taking into account certain obligations of a business entity that is disregarded as separate from its owner under section 856(i) or section 1361(b)(3) of the Internal Revenue Code, or Sec. Sec. 301.7701-1 through 301.7701-3 of the Procedure and Administration Regulations. These final regulations clarify the existing regulations concerning when a partner may be treated as bearing the economic risk of loss for a partnership liability based upon an obligation of a disregarded entity. The rules affect partnerships and their partners.

Source

Authoritative
Federal Register document
Machine
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