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
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
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
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
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