The final, temporary, and proposed regulations issued by the Internal Revenue Service on October 13 relating to intercompany debt obligations between members of an affiliated group of corporations under Section 385 of the...more
11/3/2016
/ Collateralized Debt Obligations ,
Corporate Counsel ,
Foreign Corporations ,
Intercompany Transactions ,
Internal Revenue Code (IRC) ,
IRS ,
Multinationals ,
Parent Corporation ,
Private Equity ,
Proposed Regulation ,
Registered Investment Companies (RICs) ,
REIT ,
S-Corporation ,
Section 385 ,
Stocks
All partnerships will be audited at the entity level unless they have 100 or fewer partners AND no partnerships as direct partners.
The two-year budget plan passed by Congress on October 30, 2015, and expected to be...more
11/3/2015
/ Audits ,
Barack Obama ,
Federal Budget ,
Federal Taxes ,
Indemnification ,
IRS ,
New Legislation ,
Participation Agreements ,
Partnership Agreements ,
Partnerships ,
Repeal ,
Tax Deductions ,
Tax Liability ,
TEFRA ,
U.S. Treasury
The principal effect of the rules would be to turn virtually any contribution of appreciated property by a US person to a section 721(c) partnership into a taxable gain recognition event.
On August 6, the US Treasury...more