The Internal Revenue Service (IRS) and the Treasury Department have issued final regulations regarding the recourse liabilities of partnerships and rules for related persons, effective December 2, 2024. These rules clarify how to allocate partnership liabilities among partners when there is overlapping economic risk of loss (EROL) and address scenarios involving tiered partnerships and related parties. The regulations also introduce an ordering rule to determine the application of different rules and allow partnerships to apply these changes to liabilities on tax returns filed after December 2, 2024, with consistent application to all partnership liabilities. Additionally, comments were requested on the potential need for further guidance regarding liability reallocations in specific transactions.
Simple Explanation
The IRS and Treasury Department made new rules to explain how money problems in partnerships are shared, especially when friends or family members are involved, starting December 2, 2024. These rules help decide who owes what and ask people if more help is needed to understand tricky money swaps.