Rev. Rul. 2019-24, page 1004.

This Revenue Ruling provides guidance on the tax treatment of virtual currency hard forks. This Revenue Ruling provides that a hard fork not followed by an airdrop of units of a new cryptocurrency does not result in gross income to owners of the original cryptocurrency. This Revenue Ruling further provides that a hard fork followed by an airdrop of units of a new cryptocurrency results in gross income to the recipients of units of new cryptocurrency from the airdrop.

T.D. 9876, page 1005. This document contains final regulations concerning how partnership liabilities are allocated for disguised sale purposes. The regulations replace existing temporary regulations with final regulations that were in effect prior to the temporary regulations. These regulations affect partnerships and their partners.

T.D. 9877, page 1007. This document contains final regulations addressing when certain obligations to restore a deficit balance in a partner’s capital account are disregarded under section 704 of the Internal Revenue Code (Code), when partnership liabilities are treated as recourse liabilities under section 752, and how bottom dollar payment obligations are treated under section 752. These final regulations provide guidance necessary for a partnership to allocate its liabilities among its partners. These regulations affect partnerships and their partners.