federal_register: E8-25851

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E8-25851 Section 108(e)(8) Application to Partnerships Proposed Rule This document contains proposed regulations relating to the application of section 108(e)(8) of the Internal Revenue Code (Code) to partnerships and their partners. These regulations provide guidance regarding the determination of discharge of indebtedness income of a partnership that transfers a partnership interest to a creditor in satisfaction of the partnership's indebtedness (debt-for-equity exchange). The proposed regulations also provide that section 721 applies to a contribution of a partnership's recourse or nonrecouse indebtedness by a creditor to the partnership in exchange for a capital or profits interest in the partnership. This document also provides notice of a public hearing on these proposed regulations. 2008-10-31 2008 10 https://www.federalregister.gov/documents/2008/10/31/E8-25851/section-108e8-application-to-partnerships https://www.govinfo.gov/content/pkg/FR-2008-10-31/pdf/E8-25851.pdf Treasury Department; Internal Revenue Service 497,254 This document contains proposed regulations relating to the application of section 108(e)(8) of the Internal Revenue Code (Code) to partnerships and their partners. These regulations provide guidance regarding the determination of discharge of...  

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