Today, Treasury and the IRS issued proposed regulations addressing when the obligations of a foreign partnership will be treated as United States property under the subpart F rules.  The proposed regulations treat an obligation of a foreign partnership as an obligation of its partners for purposes of section 956, subject to an exception for obligations of foreign partnerships in which neither the lending CFC nor any person related to the lending CFC is a partner.  Under the regulations, a partner’s share of a partnership obligation is determined by reference to the partner’s interest in partnership profits.  The regulations will generally be effective for taxable years of CFCs ending on or after the publication of final regulations, and taxable years of United States shareholders in which or with which such taxable years end, with respect to property acquired, or pledges or guarantees entered into, on or after the date on which final regulations are published.