Better Twice Measured: Partner Basis from Partnership Debt
23 Pages Posted: 27 May 2015
Date Written: April 6, 2015
Abstract
Johnson argues that the current regulations under section 752 allow free trade in the purchase and sale of naked deductions, which should be ended. Johnson argues that proposed new regulations should not allow any nonrecourse partnership liability to be allocated to a partner who has a zero or negative capital account and no claim on equity, because Crane requires an equity interest for the debt to be considered a burden under economic substance. Johnson concludes that Treasury should fix the current regulations without involving Congress.
Suggested Citation: Suggested Citation
Johnson, Calvin Harsha, Better Twice Measured: Partner Basis from Partnership Debt (April 6, 2015). Tax Notes, Vol. 146, No. 9, 2015, U of Texas Law, Public Law Research Paper No. UTPUB628, Available at SSRN: https://ssrn.com/abstract=2611361 or http://dx.doi.org/10.2139/ssrn.2611361
Do you have negative results from your research you’d like to share?
Feedback
Feedback to SSRN
If you need immediate assistance, call 877-SSRNHelp (877 777 6435) in the United States, or +1 212 448 2500 outside of the United States, 8:30AM to 6:00PM U.S. Eastern, Monday - Friday.