For purposes of section 752, the following definitions apply: (1) Recourse liability defined. A partnership liability is a recourse liability to the extent that any partner or related person bears the economic risk of loss for that liability under § 1.752-2. (2) Nonrecourse liability defined.

(a) Partner's share of recourse liabilities — (1) In general. A partner 's share of recourse partnership liability equals the portion of that liability, if any, for which the partner or related person bears the economic risk of loss.

For purposes of section 752, the following definitions apply: (1) Recourse liability defined. A partnership liability is a recourse liability to the extent that any partner or related person bears the economic risk of loss for that liability under § 1.752-2. (2) Nonrecourse liability defined.

In amending the regulations prescribed under section 752 of such Code to reflect subsection (a), the Secretary of the Treasury or his delegate shall prescribe regulations relating to liabilities, including the treatment of guarantees, assumptions, …

§1.752–7 Partnership assumption of partner’s §1.752–7 liability on or after June 24, 2003. (a) Purpose and structure. (b) Definitions. (1) Assumption. (2) Adjusted value. (3) §1.752–7 liability. (i) In general. (ii) Amount and share of §1.752–7 liability. (iii) Example. (4) §1.752–7 liability transfer. (i) …

Rev. Rul. 94-4, 1994-1 C.B. 196, holds that a deemed distribution of money under § 752(b) resulting from a decrease in a partner's share of the liabilities of a partnership is treated as an advance or drawing of money under § 1.731-1(a)(1)(ii) to the extent of the partner's distributive share of income for the partnership taxable year.

2024年12月2日 · When determining a partner's share of partnership liabilities, the existing regulations under section 752 (existing §§ 1.752-1 through 1.752-3) distinguish between two categories of liabilities—recourse and nonrecourse.

2019年10月9日 · Section 752 separates partnership liabilities into two categories: Recourse liabilities and nonrecourse liabilities. Section 1.752-1 (a) (1) provides that a partnership liability is a recourse liability to the extent that any partner or related person bears the economic risk of loss (EROL) for that liability under § 1.752-2.

2 天之前 · Read Code Section 752—determining tax treatment of certain partner liabilities. Access regulations, history and the full-text Sec. 752 of the IRC on Tax Notes.

2000年10月31日 · Treasury regulation § 1.752-3 currently provides a three-tiered system for allocating nonrecourse liabilities. The three-tiered system applies sequentially. Under the first tier, a partner is allocated an amount of the liability equal to that partner's share of partnership minimum gain under section 704 (b). See § 1.704-2 (g) (1).