The proposed regulations provide that
the transfer of a partnership interest in connection with the
performance of services is subject to section 83 of the Internal
Revenue Code (Code) and provide rules for coordinating section 83
with partnership taxation principles. The proposed regulations also
provide that no gain or loss is recognized by a partnership on the
transfer or vesting of an interest in the transferring partnership
in connection with the performance of services for the transferring
partnership.
US Code:
26 USC
83 Name of Law: Property transferred in connection with
performance of services.
US Code: 26
USC 721 Name of Law: Nonrecognition of gain or loss on
contribution
US Code: 26
USC 7805 Name of Law: Rules and regulations.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.