Too Big to Fail: The Problem of Partnership Allocations (Part 2‪)‬

III. THE RETURN OF PARTNERSHIP ALLOCATIONS This Part explores the future of partnership allocations, focusing on reform of the Section 704(b) Regulations. The pendulum has swung too far toward mechanical rules and, hence, the regulations have failed to provide partnerships with a comprehensible or administrate means of making allocations. This article thus proposes that the Treasury recalibrate the Section 704(b) Regulations' regulatory design, streamlining partnership allocations by shifting to a more standard-based allocation methodology. In doing so, the Treasury would take the first and most important step towards improving partnership allocations and subchapter K as a whole.