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"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

"New Section 355 No-Rule Policies"

On January 2, 2013, the Internal Revenue Service (the Service) released Rev. Proc. 2013-3, its annual list of areas in which it no longer will issue private letter rulings or determination letters (the 2013 No-Rule List). Of...more

2/13/2013 - 2013 No-Rule List Debt Securities Debt-for-Debt Exchanges IRS North-South Transactions Private Letter Rulings Recapitalization Section 355 Shareholders Spinoffs Stocks

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