Partner Eric Sloan of Gibson Dunn recently discussed a last-minute amendment in the tax bill passed by the U.S. House of Representatives with Tax Notes. The amendment addresses whether partnership rules concerning disguised sales and fees for services are self-executing. Despite its unexpected nature, Sloan indicated that the change might not have significant practical effects.
Sloan stated, “The subchapter K crowd has essentially practiced as if the [section 707] rules were operative in the absence of regulations for a long time, largely because we have all believed that a court would use one of many routes to reach the same result, even if a court found the code provision not to be self-executing.”
Eric Sloan is Co-Chair of Gibson Dunn’s Tax Practice Group.
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