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