Kevin Feeley

Kevin Feeley

McDermott Will & Emery

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Latest Publications


Treasury Finalizes Regulations on the Varying Interests Rule Under Section 706

On August 3, 2015, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations under Section 706(d), providing rules for determining the partners’ distributive shares of...more

10/20/2015 - Distribution Rules Final Rules Internal Revenue Code (IRC) IRS New Regulations Partnerships Pro Rata Allocation Rule Proposed Regulation U.S. Treasury

Proposed Regulations Require Significant Entrepreneurial Risk for a Service Partner's Income to be a Distributive Share

On July 22, 2015, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released proposed regulations under Section 707(a)(2)(A) (the proposed regulations) which would treat certain partnership...more

8/20/2015 - Distribution Rules Fee Waivers IRS Management Fees Partnerships Personal Services Profits Interests Significant Entrepreneurial Risk (SER) U.S. Treasury

Section 752 Proposed Regulations Regarding Partnership Recourse Liabilities and Rules for Related Persons

On December 13, 2013, the Internal Revenue Service and U.S. Department of the Treasury issued proposed regulations under Section 752 regarding recourse liabilities of a partnership and the special rules for related persons...more

1/28/2014 - IRS Partnerships Proposed Regulation U.S. Treasury

For Private Equity Investors, Section 1202 May Be Worth Another Look

Included in the American Taxpayer Relief Act of 2012 (ATRA) are provisions that extended some of the more significant benefits of Internal Revenue Code Section 1202, the Code provision that permits eligible noncorporate...more

3/22/2013 - Alternative Minimum Tax American Taxpayer Relief Act Equity Investors Non-Taxable Income Qualified Small Business Stock

Treasury Finalizes Regulations on Noncompensatory Partnership Options

The U.S. Treasury Department recently released regulations on the tax treatment of noncompensatory options issued by a partnership, as well as proposed regulations addressing the threshold question of when a partnership...more

2/27/2013 - Business Taxes Capital Gains Capital Losses Exercise of an Option IRS Noncompensatory Partnership Options Partnership Interests Partnerships U.S. Treasury

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