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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

What Is Carried Interest?

During the second presidential debate, one of the few things that both candidates agreed on was doing away with carried interest as part of their proposed tax changes. But they never explained what it is. So what was is...more

Could Your Project Utilize New Market Tax Credits?

I came home from work the other day and my middle child had a kitten in her arms. A mangy, dirty, little dark scrawny kitten…gross. I’m not a cat person. OK, that’s not completely accurate. I friggin’ hate cats. The world...more

Partnership Tax Audit Reform and Private Funds

The Bipartisan Budget Act of 2015 that was signed into law on November 2, 2015, made extensive changes to the rules that apply to partnership audits and the mechanics for collecting taxes resulting from an audit. These...more

There is life after death...of the Bottom-Dollar Guarantee

Seyfarth Synopsis: On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other partnership tax issues, including “bottom-dollar”...more

Corporate Finance Alert: SEC Staff Continues to Focus on Non-GAAP Financial Disclosures

In recent months, companies have experienced greater scrutiny of their use of non-GAAP financial measures by the staff of the U.S. Securities and Exchange Commission (SEC). This greater scrutiny follows the release earlier...more

[Webinar] Business Planning in Light of Proposed Regulations under Code § 2704 - October 27th, 12:00p.m. CT

In this webinar, Steve Gorin, the author of his quarterly newsletter, will discuss the proposed regulations under IRC § 2704 that would increase the valuation of business entities in many cases. Attendees will learn when the...more

Tax Benefit from Leveraged Partnerships Shut Down By New IRS Regulations

On October 5, 2016, the IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged...more

New Regulations Dramatically Alter Partnership 'Disguised Sales' and Allocation of Partnership Liabilities

On October 4, 2016, the Internal Revenue Service and the Treasury Department issued a sweeping package of proposed, temporary and final regulations under the Internal Revenue Code that, among other things, significantly...more

IRS Addresses RIC Qualification Matters Related to Derivatives and Use of Blocker Corporations

On Wednesday, September 28, the IRS and Treasury Department proposed regulations under Section 851 of the Code that, if finalized, could prospectively invalidate dozens of private letter rulings treating subpart F and passive...more

IRS and Treasury Issue Guidance Regarding CFC and PFIC Investments by RICs

The recently proposed regulations, if finalized, would govern the treatment of RICs’ income inclusions in respect of CFCs and PFICs for purposes of the income test applicable to RICs; in related guidance, the IRS also...more

Global Tax News: Brazil opens consultation on how MAP provisions apply to DTT agreements

Brazil’s Federal Revenue (RFB) has opened a public consultation aimed at regulating how mutual agreement procedure (MAP) provisions apply to conventions and international agreements created to avoid double taxation....more

Digesting the €13 Billion Apple-EU Tax Ruling

King & Spalding experts assess what international businesses need to be aware of following the EC's ruling on State Aid in the Apple case - Partners in King & Spalding’s tax department have shared their perspectives and...more

Changes to PA Business Corp. Law may affect the way Commercial Real Estate is owned in PA

For decades owners of commercial real estate in Pennsylvania took title in limited partnerships, not necessarily because it was the best entity to own and manage property, but because it minimized the effect of the Capital...more

Tax Considerations for BDC Consolidation Transactions [Video]

In this video, Dechert tax partner Jeffrey S. Sion examines several important tax considerations related to business development company (BDC) consolidation transactions, including the pros and cons of taxable and tax-free...more

Investing Private Foundation Assets: What Every Foundation Manager Should Know

Those responsible for managing a private foundation’s investment assets may not always understand the unique fiduciary and tax constraints imposed on private foundations and their managers by both state and federal law....more

Update to August 24th Safe Harbors Client Alert - NEW TRANSITION PERIOD

Update to August 24th Client Alert: Note: As published September 6, 2016 in the Internal Revenue Bulletin, the Internal Revenue Service has extended the transition period with respect to Revenue Procedure 2016-44 to...more

Treasury Proposes Regulations That Would Require Private Trust Companies to Establish or Enhance AML Programs and to Identify...

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published proposed regulations on August 25, 2016 that would require certain private trust companies utilized by high net worth individuals,...more

EU tax ruling levies €13 billion state aid penalty on Apple

On 30 August 2016, Ireland was ordered by the EC to recover up to €13 billion from Apple on the basis that tax arrangements implemented between Apple and Ireland, originally in 1991, amounted to the provision of unlawful tax...more

The sukuk experience in Turkey

Turkey's government is determined to make Istanbul a financial hub for Islamic finance, regionally and globally. With a GDP of US$733.6 billion in 2015 according to the IMF, Turkey is the 18th largest economy in the world,...more

Battle Heats Up Over Who Can Regulate Tax on International Companies

In a decision that again pits the United States against the European Union in that ongoing battle over which entity can primarily tax international business, Margrethe Vestager, the European Union commissioner for...more

IRS Updates Ruling Policy on Corporate Business Purpose and Device Requirements under Section 355

The U.S. Internal Revenue Service (“IRS”) released Revenue Procedure 2016-45 (the “Revenue Procedure”) on August 26, 2016, permitting taxpayers once again to seek private letter rulings on issues of “corporate business...more

Client Alert: New Safe Harbors for Management Contracts of Tax-Exempt Financed Facilities

The Internal Revenue Service on August 22, 2016 released Revenue Procedure 2016-44 which revises the safe harbor guidelines for management contracts of service providers for tax-exempt financed facilities, under which the...more

Dubai Airport Freezone Authority

Dubai Airport Freezone (DAFZA) is one of the region’s fastest growing Freezones. Established in 1996, DAFZA is home to over 1,450 companies, covering a range of key industry sectors, including aviation, freight & logistics,...more

Duty of Consistency Doctrine - Effective Sword for the IRS, but Not Likely a Shield for Taxpayers - Tax Update Volume 2016, Issue...

Two recent cases illustrate the IRS’ ability to successfully argue that taxpayers should not benefit from their own mistakes if they result in less tax being paid. Two recent cases highlight the most current view of the...more

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