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Investment Partnerships Partnerships

Bradley Arant Boult Cummings LLP

Special Commentary: State Tax Treatment of Investment Partnerships

As we previously reported, the Multistate Tax Commission has undertaken an ambitious project on the state taxation of partnerships. Their partnership work group consists of volunteers from numerous state revenue departments,...more

Rivkin Radler LLP

Biden’s 2022 Revenue Proposal, Profits Interests, And The Alchemy Of Compensation

Rivkin Radler LLP on

Recap- Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held...more

Vicente LLP

When Is A Strategic Partnership Or Joint Venture Right For Your Cannabis Business?

Vicente LLP on

One of the biggest mistakes a cannabis and hemp business owner can make is trying to do everything alone. To ensure this mistake is avoided, business owners should first develop the right internal team, and then look to...more

Goodwin

Draft Legislation Published on UK Partnership Taxation

Goodwin on

Earlier this year, HM Revenue & Customs published various ideas to ‘clarify’ the tax treatment of partners in partnerships, as part of its response to a consultation on changes to the taxation of UK partnerships. Draft...more

Troutman Pepper

Applying the Look-Through Rules in Determining 'Investment Partnership' Status Under Section 721(b) - Tax Update Volume 2017,...

Troutman Pepper on

Careful Evaluation and Planning Should Be Undertaken When the Partnership Is Formed and When Assets Are Contributed to Evaluate the Potential Impact of Section 721(b). Many taxpayers choose partnership structures...more

Dechert LLP

Financial Services Quarterly Report - Fourth Quarter 2016: The Impact of New U.S. Partnership Audit Rules on Investment...

Dechert LLP on

The U.S. Bipartisan Budget Act of 2015 amended the provisions of the U.S. Internal Revenue Code of 1986, as amended (Code), governing partnership audit proceedings. The new provisions are designed to simplify the ability of...more

Morrison & Foerster LLP

Tax Treatment of “Bad Boy Guarantees” Challenged by Recent IRS Memorandum

I. OVERVIEW - A recently released legal memorandum by the Internal Revenue Service (IRS) Office of Chief Counsel, CCA 201606027 (the “Memorandum”), concluded that a so-called “bad boy guarantee” provided by a sponsor of...more

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