David Roby Jr.

Eversheds Sutherland (US) LLP

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A new life for leveraged partnership structures; Treasury and the IRS issue proposed regulations under the disguised sale rules

On June 19, 2018, Treasury and the Internal Revenue Service (IRS) published proposed regulations (REG-131186-17) (2018 Proposed Regulations) concerning the manner in which partnership liabilities are allocated among the...more

6/25/2018 / IRS , Partnerships , Proposed Regulation , Tax Liability , U.S. Treasury

Reversing Course—Proposed Regulations Reverse IRS Ruling Position on Treatment of Income from CFCs and PFICs for RIC Qualification...

On September 27, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (REG-123600-16) (the Proposed Regulations) under section 851 addressing the income test applicable...more

10/4/2016 / Business Development Companies , Commodities , Controlled Foreign Corporations , IRS , Passive Foreign Investment Company , Proposed Regulation , Regulatory History , Revenue Procedure 2016-50 , U.S. Treasury

Sweeping Changes Proposed to Tax Treatment of Related-Party Debt May Impact Private Funds

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would potentially treat related-party debt, in whole or in part, as equity for U.S. tax purposes. The Proposed Regulations generally apply to...more

4/15/2016 / Comment Period , Controlled Groups , Debt , IRS , Private Funds , Proposed Regulation , Related Parties , U.S. Treasury

At Last: Final Regulations Issued Under Section 336(e)

In a move that was nearly 27 years in the making, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued long-awaited final regulations under §336(e) (the Final Regulations) on May 10. Section 336(e)...more

5/14/2013 / Corporate Taxes , Distribution Rules , IRS , Proposed Regulation , Stocks

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