News & Analysis as of

Limited Liability Company (LLC) New Guidance

Farella Braun + Martel LLP

The IRS Is Targeting Partnership Transactions: Is Your Representative Ready?

Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more

Cadwalader, Wickersham & Taft LLP

American Cousins: HMRC Revisits Anson

On 12 December 2023, H.M. Revenue & Customs (“HMRC”) updated its guidance on foreign entity classification and, specifically, HMRC’s treatment of profits of, and distributions by, United States-established limited liability...more

Williams Mullen

The Virginia Department of Tax Publishes Pass-Through Entity Tax FAQs

Williams Mullen on

The Virginia Department of Taxation (Department) recently published Virginia Pass-Through Entity Tax Frequently Asked Questions for Taxable Years 2022 and After (FAQs). As summarized below, the FAQs provide helpful guidance...more

Proskauer - Not for Profit/Exempt...

IRS Releases Guidance on Requirements for Limited Liability Companies to Qualify as Tax-Exempt Entities

On October 21, 2021, the Internal Revenue Service (the “IRS”) released Notice 2021-56 (the “Notice”), which sets forth the additional requirements a limited liability company (“LLC”) must satisfy to obtain a determination...more

Bradley Arant Boult Cummings LLP

Alabama DOR Issues User-Friendly Guidance on Annual Tax License Renewals

As we noted in our previous SALT Alert, on October 1 the Alabama Department of Revenue (ADOR) quietly posted a notice on its website and shared it with media outlets that received little notoriety – at least initially. The...more

Proskauer - Tax Talks

Proposed Regulations on UBTI Provide Guidance to Tax-Exempt Organizations Making Fund Investments

Proskauer - Tax Talks on

On April 23, 2020, the Treasury Department and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 512(a)(6) of the Internal Revenue Code (the “Code”). Section...more

Patton Sullivan Brodehl LLP

“Drop and Swap” — Tax-Friendly Handling of a Dissolving LLC’s Real Property

A common LLC problem: LLC members are ready to call it quits on the LLC and divide their interests in the LLC’s real property. Some members may want to sell, receive cash, and recognize gains for tax purposes. Other...more

Hutchison PLLC

Client Alert: SBA Issues Additional Guidance for Self-Employed Individuals and PPP Borrowers Taxed as Partnerships

Hutchison PLLC on

On April 15, 2020, the U.S. Small Business Administration issued a new interim final rule (link) (the “Guidance”) that supplements prior guidance with respect to the Paycheck Protection Program (the “PPP”). Among other...more

ArentFox Schiff

Justice Department Offers New Antitrust Guidance With Lessons for Nonprofits, Associations, and Other Member-Owned and Operated...

ArentFox Schiff on

When was the last time your organization reviewed its antitrust compliance program? The Antitrust Division of the US Department of Justice announced a new policy to incentivize corporate antitrust compliance programs, which...more

Holland & Knight LLP

New Treasury Regulations Revise Taxation of U.S. Persons Owning Foreign Corporations - Guidance Will Impact Minority Partners in...

Holland & Knight LLP on

Highlights - • In an unanticipated development, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently issued regulations (New Guidance) that significantly modifies the taxation of U.S....more

Holland & Knight LLP

Tax Reform's New Incentives for Investments in Low-Income Communities: Part 2

Holland & Knight LLP on

• Part 1 of this series of Holland & Knight alerts described a new tax incentive contained in the Tax Cuts and Jobs Act for investments in low-income communities designated as "Opportunity Zones." Part 1 also explained the...more

Butler Snow LLP

IRS Reverses Position on “Bad Boy” Guarantees

Butler Snow LLP on

Earlier this year, the IRS issued Chief Counsel Advice 201606027 (February 5, 2016) concluding that, for purposes of the basis and at-risk limitations, an LLC member’s guarantee of entity-level nonrecourse debt conditioned...more

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