Final Regulations on Partnership Recourse Liabilities Bring Clarity to Certain Tax Allocations
Content by Dave Bartoletti & Rick Aderman

On December 2, 2024, the IRS published final regulations under Code[1] Sections 704 and 752 (pursuant to authority set forth in Code Section 7805(a)) relating to a partner’s share of recourse partnership liabilities, largely adopting the proposed regulations issued over a decade ago.
Introduction
Code Section 752 provides that an increase (or decrease) in a partner’s share of partnership liabilities (including via a change in a partner’s individual liabilities due to assumption of a …