The U.S. Treasury Department and the Internal Revenue Service recently released proposed regulations under Section 1061 of the Internal Revenue Code of 1986, as amended.1 Congress enacted Section 1061 in 2017 in order to...more
8/26/2020
/ APIs ,
Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Holding Periods ,
Internal Revenue Code (IRC) ,
IRS ,
Partnership Interests ,
Pass-Through Entities ,
Proposed Regulation ,
Recharacterization ,
U.S. Treasury
The Treasury Department and Internal Revenue Service recently issued proposed regulations (the Proposed Regulations) and Revenue Ruling 2018-29 (the QOZ Revenue Ruling), providing much anticipated guidance for Qualified...more
The Treasury issued new final, temporary and proposed regulations that take aim at, and significantly reduce the effectiveness of, leveraged partnership structures intended to achieve tax deferral to the contributing partner....more
Under FIRPTA, a non-U.S. person’s gain from the sale of U.S. real property interests is treated as income that is effectively connected with a U.S. trade or business (“ECI”), and therefore, is subject to U.S. federal income...more
Late last month, the Treasury Department issued proposed regulations that address partnership liabilities (section 752) and disguised sales of property (Internal Revenue Code section 707). If enacted, the section 752...more