The ABA submitted comments on proposed regulations issued under Section 514 (the Fractions Rule), addressing the extent to which a tax-exempt organization’s income with respect to “debt-financed property” is treated as unrelated business taxable income in the case of real property held by certain tax-exempt organizations. The ABA also submitted comments regarding the need for published guidance with respect to Sections 864(c)(8) and 1446(f), which were added by the TCJA. Section 864(c)(8)(A) provides that gain or loss of a nonresident alien individual or foreign corporation from the sale, exchange or other disposition of a directly or indirectly held partnership interest shall be treated as effectively connected to the extent that such gain or loss does not exceed the gain or loss such person would have recognized as effectively connected gain or loss had the partnership sold all of its assets at their fair market value as of the date of the transfer. Section 1446(f) provides that if any portion of the gain (if any) on a disposition of an interest in a partnership would be treated under Section 864(c)(8) as income effectively connected with the conduct of a trade or business within the U.S., the transferee of the partnership interest must withhold tax equal to 10 percent of the amount realized on the disposition.