Certain Distributions Treated as Sales or Exchanges
DEPARTMENT OF THE TREASURY
Internal Revenue Service
This document contains proposed regulations that prescribe how a partner
should measure its interest in a partnership’s unrealized receivables and inventory
items, and that provide guidance regarding the tax consequences of a distribution that
causes a reduction in that interest. The proposed regulations take into account
statutory changes that have occurred subsequent to the issuance of the existing
regulations. The proposed regulations affect partners in partnerships that own
unrealized receivables and inventory items and that make a distribution to one or more partners.
https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-25487.pdf