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Joint Venture Partnerships Internal Revenue Service

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

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

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

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