Corporate Taxes Partnerships

News & Analysis as of

Focus on Tax Strategies & Developments - October 2015

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

MoFo New York Tax Insights - Volume 6, Issue 10

State Tax Department Releases Draft Article 9-A Nexus Regulations Under Corporate Tax Reform - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise...more

Tax Review - September 2015

We are proud to present the next edition of our “Tax Review” which contains a selection of rulings and interpretations that had been issued or published in August 2015. We hope you will find the information provided here...more

Corporate Alert: The Luxembourg Special Limited Partnership

Largely inspired by the Anglo-Saxon limited partnership regimes, the special limited partnership (SLP) has been designed to bolster Luxembourg’s position as the main alternative investment fund structuring hub in the EU at a...more

Important Tax Provisions of Extended Highway Trust Fund Act

The “Surface Transportation and Veterans Health Care Choice Improvement Act of 2015? (P.L. 114-41, “the Act”) became law on July 31, 2015. Designed as a 3-month extension of the Highway Trust Fund and related measures, the...more

Treasury and IRS Release Notice 2015-54: Potential Impact on Domestic and Foreign Partnerships

The principal effect of the rules would be to turn virtually any contribution of appreciated property by a US person to a section 721(c) partnership into a taxable gain recognition event. On August 6, the US Treasury...more

Tax Law Blog: Deadline Days Shuffle for Many Business Tax Returns

A highway-funding bill passed by the Senate on July 30, 2015, and signed by President Obama on July 31st, contained certain tax provisions that change the due date of tax returns for many businesses. The bill, H.R. 3236,...more

German Investment Taxation – Reform Ahead

The German Ministry of Finance (Bundesfinanzministerium) circulated a discussion draft bill on the reform of fund taxation (‘Draft Bill’) on 22 July 2015. The Draft Bill contains significant changes to the German tax...more

Inside the New York Budget Bill: Department Issues Guidance Regarding Investment Capital Identification Procedures

On July 7, 2015, the New York Department of Taxation and Finance issued guidance (TSB-M-15(4)C, (5)I, Investment Capital Identification Requirements for Article 9-A Taxpayers) on the identification procedures for investment...more

Master Limited Partnership Parity Act Reintroduced To House And Senate

On June 24, 2015, the Master Limited Partnership Parity Act (S. 1656) was reintroduced in the House and the Senate. The legislation would provide investors in renewable energy projects with tax breaks that are currently...more

Partnership Rules Not Applicable to Determining Recourse vs Nonrecourse Status of Debt Outside of Subchapter K

Code Section 752 and its regulations provide extensive rules as to determining whether partnership debt is recourse or nonrecourse. Such determinations are relevant for basis determination purposes under Subchapter K (the...more

Publicly Traded Partnership Proposed Regulations

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

Guaranteed Payments: the Equivalent of a Salary for LLC Members and Partners

Absent special elections to be taxed differently, partnerships and limited liability companies (referred to herein as “entities”) with two or more partners or members (referred to herein as “owners”) are taxed on a...more

Recent U.S. Tax Developments Affecting Publicly Traded Partnerships

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

Locke Lord QuickStudy: The Fate of Partnerships Under President Obama’s 2016 Proposed Budget

On Monday, February 2, President Obama formally released his 2016 budget proposal and, as expected, it contained numerous changes to the Internal Revenue Code. ...more

TEFRA, Sometimes Forgotten But Not Gone

The Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”), as codified in Internal Revenue Code. § 6221, et seq., (“IRC”) is sometimes lost in the maze of more recent tax enactments. But, occasionally, it does rear its...more

MoFo New York Tax Insights - Volume 5, Issue 12 - December 2014

In This Issue: - ALJ Rejects New York City’s Attempt to Forcibly Combine Bank and Its Non-New York City Mortgage Subsidiary - Tribunal Amends Decision Upholding Disallowance of Nonresident Partner’s Loss from...more

Southeast State & Local Tax: Important Developments - September/October 2014

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA - INDIVIDUAL INCOME TAX...more

Doing Business in Canada

This Guide provides non-Canadians with an introduction to the laws and regulations that affect the conduct of business in Canada and, in particular, in the province of Ontario. In some cases, this Guide also identifies issues...more

Summary of IC-DISC Tax Benefits

Interest-Charge Domestic International Sales Corporations (“IC-DISCs”) offer significant potential tax benefits for U.S. companies that export U.S. manufactured products or certain engineering or architectural services with...more

For Love or Charity – A Charitable Bailout Using Charitable Remainder Trusts for the Sale of a C Corporation

I have personally observed in my professional travels that many taxpayers are reluctant charitable donors. However, we you remind a business owner that they only have three choices when it comes to taxes (1) Pay yourself;...more

Cross-Border Interest Expense Apportionment Regulations Finalized

The IRS issued cross-border interest apportionment final regulations. These adopt the approach from the 2012 temporary regulations, requiring a 10% corporate partner to apportion its interest expense by reference to the...more

Supreme Court Decides United States v. Clarke

On June 19, 2014, the United States Supreme Court held that a taxpayer has the right to examine Internal Revenue Service (IRS) officials regarding their reasons for issuing a summons only if the taxpayer points to facts or...more

Proposals May Signal Direction of Future Tax Reform

After several years of hearings and forums intended to develop broad-based support for comprehensive tax reform, on February 26, 2014, House Ways and Means Committee Chairman David Camp (R-Mich.) released a draft tax reform...more

U.S. Tax Court Ruling in State Conservation Tax Credit Case Requires Income Recognition

In its recently issued opinion in the case of Route 231, LLC v. Commissioner, T.C. Memo 2014-30 (2/24/14), the United States Tax Court (the “Court”) held that a transfer of state tax credits to a 1% member who had contributed...more

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