On July 15, 2014, the Internal Revenue Service released T.D. 9676, the final rules on the allocation and apportionment of interest expense by corporations owning a 10% or higher interest in a partnership.  The rules are intended to limit the ability of taxpayers to get inappropriate tax benefits under the fair market value of allocation.  The rules also provide guidance on using the fair market value method to allocate and apportion interest expense and serve to update the interest expense rules.  In addition to impacting corporate partners, individual partners may also be subject to the requirements of the rules if an individual acts as a general partner or the person’s direct and indirect interest in the partnership is 10 percent or more.  The final rules are scheduled for publication in the Federal Register on July 16, 2014, which is also the date on which they go into effect.