Final Regulations on Partnership Debt-for-Equity Exchanges

McDermott Will & Emery
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The U.S. Department of the Treasury recently issued final regulations providing helpful clarifications on the partnership and partner level tax consequences of debt-for-equity exchanges.

On November 15, 2011, the U.S. Department of the Treasury (DOT) issued final regulations governing the federal income tax treatment of a transaction in which a partnership issues a partnership interest to a creditor in satisfaction of the partnership’s indebtedness. These regulations largely follow the approach taken in the proposed regulations issued in 2008, but with some helpful clarifications added.

Please see full publication below for more information.

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