President Trump signed into law tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”) on December 22, 2017. The Tax Act implemented the most far-reaching changes to the Internal Revenue Code (the...more
4/9/2018
/ Base Erosion Tax ,
Business Expenses ,
Capital Gains ,
Carried Interest Tax Rates ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Exports ,
GILTI tax ,
Global Market ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
Local Taxes ,
Multinationals ,
Net Operating Losses ,
Pass-Through Entities ,
Portfolio Companies ,
Private Equity ,
Private Equity Funds ,
Repatriation ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Exemptions ,
Tax Rates ,
Trump Administration
The U.S. Senate passed its version of the GOP tax reform bill, the Tax Cuts and Jobs Act (the “Senate Bill”), on Saturday, December 2, 2017. Shortly before approving the Senate Bill, the U.S. Senate adopted a Manager’s...more
12/6/2017
/ Alternative Minimum Tax ,
Carried Interest ,
Corporate Taxes ,
Deductions ,
EBITDA ,
Estate Tax ,
FIFO ,
Individual Mandate ,
International Tax Issues ,
Mortgages ,
Net Operating Losses ,
Pass-Through Entities ,
Pending Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
UBTI
The U.S. House of Representatives GOP conference released its long-awaited tax reform bill, the Tax Cuts and Jobs Act (the “House Bill”), on Thursday, November 2, 2017. ...more
11/10/2017
/ Carried Interest ,
Compensation & Benefits ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Deferred Compensation ,
Executive Compensation ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Legislative Agendas ,
Net Operating Losses ,
Pass-Through Entities ,
Proposed Legislation ,
Stock Options ,
Tax Code ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
UBTI
The U.S. Internal Revenue Service (“IRS”), on August 11, 2017, issued Revenue Procedure 2017-45 (the “New Revenue Procedure”).1 Pursuant to the New Revenue Procedure, the IRS will treat part cash and part stock distributions...more
The U.S. Treasury Department and the Internal Revenue Service (the “IRS”) have re-issued proposed regulations (the “Proposed Regulations”) on the new centralized partnership audit rules enacted as part of the Bipartisan...more
6/22/2017
/ Audits ,
Bipartisan Budget Act ,
Business Taxes ,
C-Corporation ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
S-Corporation ,
TEFRA ,
Trump Administration ,
U.S. Treasury
The IRS has recently issued Proposed Regulations under Section 851(b) of the Internal Revenue Code (the “Proposed Regulations”), and a Revenue Procedure that address the treatment to regulated investment companies (“RICs”)...more
Final U.S. Treasury regulations under Section 446 of the Internal Revenue Code of 1986, as amended (the “Code’), providing for the use of the net asset value (“NAV”) accounting method for transactions in money market fund...more
7/26/2016
/ Accounting Methods ,
Excise Tax ,
Final Rules ,
Floating NAV ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Company Act of 1940 ,
IRS ,
Money Market Funds ,
NAV ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
Widely held partnerships are a significant source of funding for oil, gas and certain natural resources projects, but the publicly traded partnership (“PTP”) rules can cause such partnerships to be treated as corporations for...more
6/24/2015
/ Corporate Taxes ,
Double Taxation ,
Energy Projects ,
Energy Sector ,
Fracking ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Partnerships ,
Master Limited Partnerships ,
Mining ,
Natural Gas ,
Oil & Gas ,
Partnerships ,
Passive Activity ,
Proposed Regulation ,
Publicly-Traded Companies ,
Qualifying Income ,
Research and Development
Federal excise taxes imposed on natural gas, propane and other alternative fuels can significantly add to their cost and can create a disincentive to their use compared with more traditional fuels such as diesel and gasoline,...more
Partnerships targeted to widespread investors are a popular investment vehicle and a significant source of funding for oil and gas projects. However, their use is affected by the publicly traded partnership (“PTP”) tax rules....more