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This document contains final regulations relating to the application of section 108(e)(8) of the Internal Revenue Code (Code) to partnerships and their partners. These regulations provide guidance regarding the determination of discharge of indebtedness income of a partnership that transfers a partnership interest to a creditor in satisfaction of the partnership's indebtedness. The final regulations also address the application of section 721 to a contribution of a partnership's recourse or nonrecourse indebtedness by a creditor to the partnership in exchange for a capital or profits interest in the partnership. Moreover, the final regulations address how a partnership's discharge of indebtedness income is allocated as a minimum gain chargeback under section 704. The regulations affect ...
President and Congress, not Super Committee, bear ultimate responsibility for America's debt and spending; 69 percent of Young Americans say Washington does not reflect their interests WASHINGTON, Nov. 21, 2011 /PRNewswire-USNewswire/ -- Generation Opportunity, one of the largest and fastest growing grassroots organizations in the nation, released results from its national poll exploring how America's young adults view the world, the American economy, and their personal futures. The Generation Opportunity poll focuses specifically on young Americans ages 18-29, popularly referred to as the "Millennial" generation. The data is particularly relevant in light of President Barack Obama's recent Asia-Pacific trip, as well as developments related to the Congressional Super Committee. It revea...
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