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Partnerships: IRS Extends Prohibition on Treating Partners as Employees

Employees of partnerships, LLCs or their disregarded entity subsidiaries who receive equity in such entities may be treated as “self-employed” for tax purposes. On May 3, 2016, the US Treasury Department (Treasury)...more

Congress Permanently Extends Capital Gains Exclusion for Qualified Small Business Stock

Tax law change is good news for non-corporate investors. On December 18, 2015, President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act) into law. The PATH Act retroactively renews and...more

OECD Publishes Final BEPS Project Reports

A focus on hybrid arrangements, interest deductions, treaty abuse and permanent establishment structures. On 5 October 2015, the OECD published its highly anticipated final reports in relation to Base Erosion and Profit...more

Tax Law Extension Good News for Non-corporate Investors

Congress once again temporarily extends the 100 percent capital gains exclusion on “qualified small business stock.” On December 19, 2014, President Obama signed the Tax Increase Prevention Act of 2014 (the 2014 TIPA)...more

IRS Proposes Significant Changes to Rules for Allocating Partnership Liabilities

Proposed Regulations seek to curtail perceived abuses, including the use of “bottom-dollar” guarantees and some indemnity arrangements. On January 29, 2014, the Internal Revenue Service (IRS) proposed regulations that...more

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