Treasury and the IRS issued proposed regulations relating to disguised payments for services under section 707(a)(2)(A).  The proposed regulations provide guidance to partnerships and their partners regarding when an arrangement will be treated as a disguised payment for services.  The preamble to the proposed regulations also indicates that the IRS intends to modify Revenue Procedures 93-27 and 2001-43 relating to the issuance of profits interests to service providers.