taxnews.ey.comPrint

10 September 2021

BREAKING TAX NEWS | Senator Wyden releases discussion draft of legislative text that would change partnership rules

Today, September 10, 2021, Senate Finance Committee Chair Ron Wyden (D-OR) released a discussion draft of legislative text that would revise sections of the tax code governing partnerships and a summary of those proposals. If enacted, the proposals, among other changes, would:

  • Mandate basis adjustments under IRC Sections 734 and 743 for partnership distributions and partnership interest sales
  • Require all partnerships to use the remedial method for IRC Section 704(c) allocations
  • Require partnerships to apply the partners'-interest-in-the-partnership (PIP) standard when determining partnership allocations, unless a new "consistent percentage method" applies
  • Require corporate tax treatment for all publicly traded partnerships
  • Generally require partnership liabilities to be allocated based on the partners' share of partnership profits

A Tax Alert is forthcoming.

Document ID: 2021-9016

 

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

 

Copyright © 1996 – 2025, Ernst & Young LLP

 

All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.

 

EY US Tax News Update Master Agreement | EY Privacy Statement