Brian Krause

Brian Krause

Skadden, Arps, Slate, Meagher & Flom LLP

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New Regulations Dramatically Alter Partnership 'Disguised Sales' and Allocation of Partnership Liabilities

On October 4, 2016, the Internal Revenue Service and the Treasury Department issued a sweeping package of proposed, temporary and final regulations under the Internal Revenue Code that, among other things, significantly...more

10/10/2016 - Capital Gains Debt Instruments Disguised Sales Internal Revenue Code (IRC) Joint Venture Master Limited Partnerships Non-Recourse Loans Partnership Liabilities Partnerships Publicly-Traded Companies REIT Tax Allocation Agreements Tax Liability Tax-Deferred Exchanges

"Treasury Releases Notice Addressing Transactions Involving Related-Party Partnerships"

On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more

8/18/2015 - Asset Transfer Business Taxes Capital Gains Cost-Sharing Foreign Affiliates Income Taxes IRS Partnerships Related Parties Section 482 Section 6662 Tax Deductions U.S. Treasury

"IRS Proposes Regulations Addressing Profits Interests, Investment Fund Fee Waiver Arrangements"

On July 23, 2015, the Internal Revenue Service (IRS) and the Treasury Department proposed regulations that address the tax treatment of certain partnership interests issued in exchange for services. Of particular note, the...more

8/5/2015 - Executive Compensation Fee Waivers Fund Managers Investment Funds IRS Partnership Agreements Partnerships Profits Interests Safe Harbors U.S. Treasury

Proposals May Signal Direction of Future Tax Reform

After several years of hearings and forums intended to develop broad-based support for comprehensive tax reform, on February 26, 2014, House Ways and Means Committee Chairman David Camp (R-Mich.) released a draft tax reform...more

4/22/2014 - Accounting Alternative Minimum Tax Corporate Taxes Debt Restructuring Derivatives Financial Products Foreign Tax Internal Revenue Code (IRC) Partnerships Subpart F Tax Credits Tax Reform Ways and Means Committee

"IRS Introduces Long-Awaited Proposed Regulations Addressing the Allocation of Partnership Liabilities and Partnership Disguised...

On January 29, 2014, the Internal Revenue Service (the IRS) and the Treasury Department (Treasury) introduced a long-awaited package of proposed regulations (the Proposed Regulations) that would significantly change the rules...more

2/26/2014 - Business Taxes IRS Partnerships Tax Liability

"House Ways and Means Proposal Would Change the Tax Treatment of Partnerships and S Corporations"

The first congressional proposals to revamp partnership and S corporation taxation in connection with anticipated tax reform have surfaced. Framed as two alternatives, both options suggest significant, and, in the case of one...more

3/29/2013

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