News & Analysis as of

Double Taxation Proposed Regulation

A&O Shearman

Notice 2024-16 Announces Limited Guidance Under Section 961(c)

A&O Shearman on

On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the...more

Snell & Wilmer

IRS Raises Impetus to Make Gifts Now With Proposed Regulations Protecting Gifts From Double Tax

Snell & Wilmer on

On November 23, 2018, the Internal Revenue Service (“IRS”) proposed new regulations that prevent individuals who make a gift of more than $5,000,000 before 2026 from being double taxed on those gifts if they die after 2026.1...more

Dechert LLP

Publicly Traded Partnership Proposed Regulations

Dechert LLP on

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

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