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Treasury Regulations · 26 CFR

§ 1.707-9. Effective dates and transitional rules.

In effect eCFR current as of October 15, 2026

Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).

Regulation under 26 U.S.C. § 707

Cite as 26 CFR § 1.707-9

At a glance

Read from the text and its source citation. Not part of the regulation.

Status
In the current eCFR
Issued
September 30, 1992 by T.D. 8439
Last amended
October 9, 2019 by T.D. 9876
Issued under
26 U.S.C. § 707
Length
529 words · about 2 min to read
Cross-references
cites 2 Code sections and 3 regulations; cited by 1
(a) Sections 1.707-3 through 1.707-6—
(1) In general. Except as otherwise provided in this paragraph (a), §§ 1.707-3 through 1.707-6 apply to any transaction with respect to which all transfers occur on or after October 5, 2016. For any transaction with respect to which all transfers that are part of a sale of an item of property occur after April 24, 1991, and any of such transfers occurs before October 5, 2016, §§ 1.707-3 through 1.707-6 as contained in 26 CFR part 1 revised as of April 1, 2016, apply.
(2) Transfers occurring on or before April 24, 1991. Except as otherwise provided in paragraph (a)(3) of this section, in the case of any transaction with respect to which one or more of the transfers occurs on or before April 24, 1991, the determination of whether the transaction is a disguised sale of property (including a partnership interest) under section 707(a)(2) is to be made on the basis of the statute and the guidance provided regarding that provision in the legislative history of section 73 of the Tax Reform Act of 1984 (Pub. L. 98-369, 98 Stat. 494). See H.R. Rep. No. 861, 98th Cong., 2d Sess. 859-62 (1984); S. Prt. No. 169 (Vol. I), 98th Cong., 2d Sess. 223-32 (1984); H.R. Rep. No. 432 (Pt. 2), 98th Cong., 2d Sess. 1216-21 (1984).
(3) Effective date of section 73 of the Tax Reform Act of 1984. Sections 1.707-3 through 1.707-6 do not apply to any transfer of money or other consideration to which section 73(a) of the Tax Reform Act of 1984 (Pub. L. 98-369, 98 Stat. 494) does not apply pursuant to section 73(b) of that Act.
(4) Applicability date of § 1.707-5(a)(2) and (f)(2), (3), (7), and (8).
(i) Section 1.707-5(a)(2) and (f)(2), (3), (7), and (8) apply to any transaction with respect to which all transfers occur on or after October 4, 2019. However, a partnership and its partners may apply § 1.707-5(a)(2) and (f)(2), (3), (7), and (8) to any transaction with respect to which all transfers occur on or after January 3, 2017.
(ii) For any transaction with respect to which any transfers occur before January 3, 2017, § 1.707-5(a)(2) and (f), as contained in 26 CFR part 1 revised as of April 1, 2016, apply.
(iii) For any transaction with respect to which all transfers occur on or after January 3, 2017, and any of such transfers occurs before October 4, 2019, see § 1.707-9T(a)(5) as contained in 26 CFR part 1 revised as of April 1, 2019.
(b) Section 1.707-8 disclosure of certain information. The disclosure provisions described in § 1.707-8 apply to transactions with respect to which all transfers that are part of a sale of property occur after September 30, 1992.

[T.D. 8439, 57 FR 44989, Sept. 30, 1992, as amended by T.D. 9788, 81 FR 69288, Oct. 5, 2016; T.D. 9787, 81 FR 69300, Oct. 5, 2016; 83 FR 50259, Oct. 5, 2018; T.D. 9876, 84 FR 54029, Oct. 9, 2019]

Other regulations under § 707

Cross-references

Computed from the citations in the text of 26 CFR.

Code sections it cites

Regulations it cites

Cited by 1 other regulation

Amendment history

From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.

  1. Amended by T.D. 9876 (84 FR 54029)
  2. Amended (83 FR 50259)
  3. Amended by T.D. 9787 (81 FR 69300)
  4. Amended by T.D. 9788 (81 FR 69288)
  5. Issued by T.D. 8439 (57 FR 44989)

Where it sits in 26 CFR

  1. Subchapter A Income tax
  2. Part 1 Income taxes
  3. Partners and partnerships

Nearby sections