Karen Turk

Karen Turk

Goodwin

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Treasury Targets Tax Deferral in Leveraged Partnership Structures with New Regulations

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

10/20/2016 - Disguised Sales Limited Liability Company (LLC) New Regulations Partnerships Private Equity Tax Deferral U.S. Treasury

New FIRPTA Changes Provide Significant Opportunities, But No Panacea for Encouraging Non-U.S. Investment in U.S. Real Estate

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

1/29/2016 - FIRPTA Income Taxes Pension Funds Protecting Americans from Tax Hikes (PATH) Act REIT Tax Returns Withholding Tax

Proposed Treasury Regulations Could Significantly Impact Tax Deferral in Partnership Transactions

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

2/4/2014 - IRS Partnerships Tax Deferral U.S. Treasury

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