News & Analysis as of

General Partnerships Internal Revenue Service

Buckingham, Doolittle & Burroughs, LLC

LLC Operating Agreements And Partnership Agreements Should Be Amended To Address New Law

If you signed an LLC operating or partnership agreement prior to January 1, 2018, it may need to be amended to accommodate a significant new rule regarding taxation of partnerships. Effective for tax years beginning after...more

Ervin Cohen & Jessup LLP

Converting a Profits (or Carried) Interest Into a Capital Interest Tax-Free, Even if it is a Marketable Security

In CCA 201517006 (dated 10/9/14 and released 4/24/15), the general partner of a publicly traded partnership (PTP) had, in addition to its capital interest, a profits interest in the PTP called “incentive distribution rights”...more

Goulston & Storrs PC

IRS Will Not Follow Partner COD Bankruptcy Exception Cases

Goulston & Storrs PC on

In a new Action on Decision (AOD 2015-10), the IRS stated that it will not follow the Tax Court’s 2004 Martinez decision, which had allowed a general partner to exclude cancellation of debt (COD) income from a partnership in...more

Latham & Watkins LLP

Four Trends in Master Limited Partnership M&A in 2014

Latham & Watkins LLP on

MLP merger and acquisition activity can take a number of different forms to unlock value for sponsors and unitholders. Background - In the first half of 2014, master limited partnership (MLP) mergers and...more

Jackson Walker

IRS: Investment Fund Managers are Subject to Self-Employment Tax

Jackson Walker on

The Office of Chief Counsel of the Internal Revenue Service (the "IRS") recently issued internal guidance in the form of a Chief Counsel Advice (the "CCA") indicating that the IRS has taken the position that the "limited...more

5 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide