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Treasury and the IRS have released final regulations under Section 987 and submitted them for publication in the Federal Register on May 13, 2019.

Of particular interest, the final regulations are narrow in scope and address three particular issues: (i) combinations and separations of Section 987 qualified business units (QBUs), (ii) withdrawal of the liquidation value percentage methodology set forth in Treas. Reg. sec. 1.987-7T, addressing allocation of assets and liabilities in the context of aggregate partnerships, and (iii) finalization of Treas. Reg. sec. 1.987-12T, anti-abuse rules. These final regulations do not amend and do not finalize other sections of the temporary Section 987 regulations.