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Ezra Dyckman and Daniel W. StahlEzra Dyckman and Daniel W. Stahl (NYLJ/Rick Kopstein)

The Treasury Department issued new regulations in October 2016 that modify a number of the partnership debt allocation rules. One important aspect of these regulations, discussed in our last column, disregards so-called “bottom guarantees” for purposes of allocating partnership liabilities among the partners of a partnership. The new regulations take an even more drastic approach, though, with respect to determining a partner’s share of partnership liabilities for purposes of the “disguised sale” rules—and in a surprising twist cause some partnership liabilities to not be included in any partner’s share.

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