News & Analysis as of

Partnerships

Reissuance of Proposed Regulations on Partnership Audit Rules

by Dechert LLP on

The U.S. Treasury Department and the Internal Revenue Service (the “IRS”) have re-issued proposed regulations (the “Proposed Regulations”) on the new centralized partnership audit rules enacted as part of the Bipartisan...more

IRS Reissues Proposed Regulations for Centralized Partnership Audit Regime

by Morrison & Foerster LLP on

The new rules represent a complete overhaul of partnership audit, assessment, and collection procedures. Taxpayers should review and potentially amend partnership agreements before the new rules are scheduled to take effect...more

Is Your Partnership Ready For IRS Audit Changes?

Businesses across the nation are buzzing about Congressional action on tax reform - action that may not even occur. And yet, many partnerships and limited liability companies (LLCs) have not yet delved into significant IRS...more

Proposed Regulations Re-Released for Centralized Partnership Audit Rules

by Locke Lord LLP on

New partnership audit rules enacted into law on November 2, 2015 (the “Centralized Partnership Audit Rules”) (previously discussed in our QuickStudy: Bipartisan Budget Act of 2015 Changes Audit Rules for Private Equity and...more

SEIA’s Finance & Tax Seminar Soundbites

Below are soundbites from panelists at the Solar Energy Industries Association’s (SEIA) Finance & Tax Seminar in New York City. The seminar was held on June 1 and 2, but only comments from the second day are reflected below....more

Proposed Partnership Audit Regulations Reissued in Substantially Identical Form

by Proskauer - Tax Talks on

On June 13, 2017, the U.S. Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) re-released proposed regulations (REG 136118-15) that provide guidance on the new centralized partnership audit...more

Candidates, Contributions & Compliance in Connection with New Jersey’s 2017 Gubernatorial Election

by Genova Burns LLC on

On Tuesday, June 6th, New Jersey held its 2017 gubernatorial primary election. Voters went to the polls to choose the Republican and Democratic candidates for Governor. Now that we know that the general election will feature...more

Illinois Senate passes "privilege tax" – deadline for final action is today

by DLA Piper on

The Illinois Senate has passed SB 1719, which would impose a 20 percent "privilege tax" on fees earned by partnerships and S corporations engaged in the business of conducting "investment management services."...more

Court Affirms Jury Finding Of No Breach Of Fiduciary Duty In Partnership Dispute

by Winstead PC on

In Thunder Rose Enters. v. Kirk, the plaintiffs sued the defendant for various claims, including breach of fiduciary duty based on an alleged partnership dispute. No. 13-15-00431-CV, 2017 Tex. App. LEXIS 3481 (Tex....more

All Partnerships Need to Adapt to the New Partnership Audit Rules Now

by Hinshaw & Culbertson LLP on

Historically, partnerships and multiple-member limited liability companies ("LLCs") taxed as partnerships generally have not had to pay income taxes at the partnership level. As a result of federal tax law changes effective...more

Partnership Dissolution And A Chief Judge’s Lament

by Allen Matkins on

Decisions by U.S. District Court judges typically begin with an identification of the parties, an explanation of the procedural posture of the case, or a description of the dispute. Chief Judge Lawrence J. O’Neill, however,...more

Energy Transfer, Williams, and the Circular Ownership of Stock

It is unheard of for a deal to die at the closing table because lawyers cannot deliver a required opinion regarding a transaction that they structured and negotiated. Yet, this is exactly what happened last year when two...more

Oil & Gas Tax Alert - "Trump's 15% Pass Through Tax Proposal: Say Goodbye to Joint Operating Agreements?"

by Porter Hedges LLP on

On Wednesday, April 26, President Trump submitted his tax reform proposal which is, for now, only about 100 words long. It contemplates a number of sweeping changes to the tax code. On the business side, these include a 15%...more

Nate Smithson Provides an Update on Tax Reform

by Jackson Walker on

Jackson Walker partner Nate Smithson has prepared an updated guide to tax reform under the Trump administration. The guide covers tax brackets, deductions, capital gains, and other relevant topics in tax law. Please see...more

Suing on Behalf of People You’re Suing Can Sink a Derivative Lawsuit — Especially If You Have a Litigious Nature

by Farrell Fritz, P.C. on

The U.S. reportedly has the world’s highest number of lawyers per capita (1 for every 300 people) and the 5th highest number of lawsuits per capita (74.5 for every 1,000 people, topped only by Germany, Sweden, Israel, and...more

Treating Partners as Employees – Overview and Update

by Ballard Spahr LLP on

Limited liability companies (LLCs) have become the fastest-growing entity choice for businesses in recent years. LLCs provide flexibility in operations and distributions. However, to the surprise of many businesspeople, if an...more

Partners Beware: New Audit Rules May Have a Big Impact on Your Bottom Line. Here’s What You Need to Know and How to Protect...

by Butler Snow LLP on

The arcane rules surrounding partnership audits rarely, if ever, come up, and most people don’t even know that they exist. What once was a set of rules confined to the dark recesses of the Internal Revenue Code are now...more

[Webinar] Landmark Tax Court Self-Employment Tax Decision; Post-Mortem Planning for Business Owners; Reimbursing Deemed Owner of...

by Thompson Coburn LLP on

This free webinar will orally discuss my 1st Quarter 2017 newsletter, including: - For the first time ever, the Tax Court ruled that a member of a limited liability company was not subject to self-employment tax. We...more

Tax Round Up - April 2017

by Proskauer Rose LLP on

Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

Creating Non-Taxed “Previously Taxed Income”: The Ultimate Pre-Immigration Strategy

According to recent statistics, immigrants and their U.S.-born children now number approximately 84.3 million people, or 27% of the overall U.S. population. The countries from which the largest numbers of these individuals...more

For High-Income and International Taxpayers: Defensive Tax Planning

The Importance of Defensive Tax Planning - IRS audit criteria target high-income taxpayers, especially those with reported foreign income or foreign financial assets. Targeted high income taxpayers include...more

A Pair of Unbrotherly Business Altercations Go to Trial

by Farrell Fritz, P.C. on

Like most civil cases, the vast majority of business divorce disputes get resolved before trial, which is disappointing for us voyeurs since only at trial with live witnesses undergoing cross examination does one get the full...more

HMRC publishes responses to the consultation on Partnership taxation

by Goodwin on

The result of the HM Revenue & Custom's consultation on UK partnership taxation was released on 20 March, this is important for both fund partnerships and fund managers structured as LLPs which file UK tax returns. Although...more

March 2017: Client Alert

by Moskowitz LLP on

2016 Proof of Health Insurance: the Form 1095 Wrinkle - Under the current Affordable Care Act (ACA), all Americans must have health insurance. If you receive your health insurance through the ACA marketplace or from...more

When Love and Business Fails

by Farrell Fritz, P.C. on

When a romantic affair evolves into a business relationship, the eventual falling out can be especially messy. Even more so if the former lovers try to keep the business going after the romance ends. That is a theme from a...more

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