The IRS on Tuesday will release proposed regulations (REG-105346-03) providing guidance on the transfer of an equity interest in a partnership in connection with the performance of services.  The regs provide that the transfer of a partnership interest in connection with the performance of services is subject to § 83 and provide rules for coordinating § 83 with partnership tax principles. The reg provide that no gain or loss is recognized by a partnership on the transfer or vesting of a partnership interest in connection with the performance of services for the partnership. Additionally, the regs modify the § 704(b) regs regarding revaluations, the maintenance of the partnerships’ capital accounts, and provide for allocations upon the forfeiture of a partnership interest.