News & Analysis as of

Joint Venture Internal Revenue Service

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

McDermott Will & Emery

Weekly IRS Roundup October 21 – 25, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 21 – 25, 2019. October 21, 2019: The IRS issued a news release in which it announced the...more

Bradley Arant Boult Cummings LLP

The New Partnership Audit Rules Are Here to Stay: It’s Time to Act - Construction and Procurement Law News, Q2 2018

The January 1, 2018 effective date of the new federal partnership audit rules quietly came and went, with many of our partnership and LLC clients and their advisers hoping that the rules were just a bad dream or would at...more

Carlton Fields

Stop “Partnering” And Begin “Strategically Allying”

Carlton Fields on

Tax exempt organizations often enter into relationships with other organizations that are collaborative in nature rather than merely quid pro quo. These relationships are frequently referred to as “partnerships” by tax exempt...more

Farrell Fritz, P.C.

Checking The Box, Partnership Allocations, And Foreign Law

Farrell Fritz, P.C. on

Many of our clients, most of which are closely-held U.S. businesses, are looking to expand their operations overseas. Some are venturing into foreign markets on their own, while others are joint-venturing with established...more

Bradley Arant Boult Cummings LLP

The New Partnership Audit Rules Are Here: Are You Ready? - Construction and Procurement Law News, Q3 2017

The January 1, 2018 effective date of the new federal partnership audit rules is almost here, and we encourage all entities taxed as partnerships to consider addressing the issues posed by these new rules as soon as possible....more

King & Spalding

IRS Rejects Investors' Claim for Refined Coal Credits in Technical Advice

King & Spalding on

In Technical Advice Memorandum 2017-29-020 (July 21, 2017) (the “TAM”), the IRS denied claims by two tax equity investors (the “Investors” or each an “Investor”) for renewable energy tax credits on grounds that the...more

Farrell Fritz, P.C.

Contributing Encumbered Assets: Partnership Disguised Sale Rules

Farrell Fritz, P.C. on

Many of our posts this year have considered some of the unique issues that are presented by a partner’s contribution of property to a partnership, including the application of the “disguised sale” rules. Today, we will...more

Clark Hill PLC

It’s a Wonderful Life – Or is it? The Taxation of Crowdfunding

Clark Hill PLC on

Every holiday season, I, like many other Americans, watch Frank Capra’s classic, It’s a Wonderful Life. While the movie has a number of iconic scenes, the most heartwarming scene occurs at the end, as the citizens of Bedford...more

Allen Matkins

Recent Changes to the Tax Matters Partner Designation May Prove Costly to the Unwary

Allen Matkins on

One choice all joint venture devotees face in negotiating each new venture is who to designate as the tax matters partner. Recent changes to the law make this decision much more important and may prove costly to those who are...more

Manatt, Phelps & Phillips, LLP

How to Get in on the Offshore Fund Flow to the U.S.

A recent report estimates that foreign investors are expected to spend more than $70 billion on U.S. commercial real estate in 2015. Another report states that nearly a quarter of all recent commercial real property sales in...more

Proskauer - Not for Profit/Exempt...

New Flexibility for Joint Ventures Using Tax-Exempt Bond-Financed Property

On October 26, 2015, the IRS released final regulations under Sections 141 and 145 of the Internal Revenue Code concerning the use of property financed with tax-exempt bond proceeds. The bulk of the new regulations fill a...more

Carlton Fields

Domestic Partnership Agreements: Financial Disclosures and Privacy

Carlton Fields on

To reduce risk of later attack on the domestic partnership agreement, domestic partners should make fair and reasonable financial disclosures to each other prior to signing the agreement. Each partner should disclose to the...more

Goulston & Storrs PC

New Restrictions on Transferring Appreciated Property to Partnerships With Related Foreign Partners

Goulston & Storrs PC on

The IRS issued Notice 2015-54 stating that it plans to issue regulations under Section 721(c) to ensure that U.S. taxpayers do not use partnerships to shift built-in gains to non-U.S. affiliates. In 1997 Congress authorized...more

Goulston & Storrs PC

IRS Finalized and Also Proposed More Partnership “Varying Interest” Regulations

Goulston & Storrs PC on

In T.D. 9728 the IRS finalized the 2009 proposed § 706(d) regulations relating to how partnerships should allocate tax items to take into account a variance in a partner’s interest during a year. A typical example is when a...more

Pillsbury Winthrop Shaw Pittman LLP

Ancillary Joint Ventures Involving Taxable and Tax-Exempt Health Care Entities: Addressing the Chilling Effect of IRS Inaction

Tax-exempt health care systems facing growing operating costs and falling revenues frequently explore creation of ancillary joint ventures (AJVs) as vehicles to raise capital, share risk, expand coverage, and provide care...more

McDermott Will & Emery

IRS Office of Chief Counsel Treated Collaboration Arrangement as Partnership

McDermott Will & Emery on

In a newly released Chief Counsel Advice, the Internal Revenue Service (IRS) Office of Chief Counsel treated a collaboration arrangement relating to the development and commercialization of a drug as a deemed partnership for...more

17 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