IRS Final Regulations on Section 752: Key Updates for Partner’s Share of Recourse Liability
REGULATION 12/22/2024 On December 2, 2024, the IRS issued final regulations (TD 10014) under Section 752, providing long-awaited clarity on how to determine a partner’s share of recourse liabilities in partnerships. These regulations address three critical areas: These updates resolve ambiguities in prior rules, particularly around the allocation of economic risk of loss among related …