Individual Comments on Proposed Corporate Partner Antiabuse Rules
Individual Comments on Proposed Corporate Partner Antiabuse Rules
- Code Sections
- Subject Area/Tax Topics
- Jurisdictions
- Tax Analysts Document Number2019-15210
- Tax Analysts Electronic Citation2019 TNT 76-23
PUBLIC SUBMISSION
Docket: IRS-2019-0015
Partnership Transactions Involving Equity Interests of a Partner (REG-135671-17)
Comment On: IRS-2019-0015-0001
Partnership Transactions Involving Equity Interests of a Partner
Document: IRS-2019-0015-0002
Comment from Anonymous Anonymous,
Submitter Information
Name: Anonymous Anonymous
General Comment
The proposed rule is similar to flow through taxation rules. Currently partners can avoid certain tax penalties through the use of corporate gains; however, this rule would make that no longer possible. While this would help raise tax revenue and would eliminate the ability for partners to realize some gains free of tax the structure of a partnership would make this rule ineffective. Additionally, partners are heavily invested financially in their businesses and are already responsible for the tax burden of the business. This rule would just increase the personal taxes of the partners and would be gains that have already been taxed at the corporate level.
- Code Sections
- Subject Area/Tax Topics
- Jurisdictions
- Tax Analysts Document Number2019-15210
- Tax Analysts Electronic Citation2019 TNT 76-23