Partnerships

News & Analysis as of

Guide To Doing Business in Australia: Major Forms Of Business Organisation (Update)

A foreign company or investor proposing to establish a business in Australia may choose from a number of different entities or forms of business organisation. Each of these forms has its advantages and disadvantages....more

New Rules on MLPs & Qualifying Income: What Oil Services and Exploration Companies Need to Know

On Tuesday, May 5, 2015, the Internal Revenue Service (“IRS”) released proposed regulations defining qualifying income for Master Limited Partnerships (“MLPs”). MLPs are publicly traded partnerships that are taxed as a...more

IRS Proposes Guidance for Determining MLP Qualifying Income

Proposed regulations seek to provide rules for determining MLP qualifying income from certain activities and services performed with respect to minerals or natural resources. On May 5, 2015, the Internal Revenue...more

Upper Tribunal Decision in Samarkand and Proteus

The long-awaited Upper Tribunal Decision in the Samarkand and Proteus case has been published. The case relates to statutory sale and leaseback partnerships with partners claiming losses under the film acquisition relief...more

Court Holds Taxpayer is Partner for Self-Employment Tax After Election Out Of Subchapter K

The Tax Court recently ruled that a taxpayer was liable for self employment tax based on its status as a partner, even though the partnership had elected out of the partnership tax rules....more

It’s All About the Process: Lessons from Delaware Court on MLP’s Conflicts Committee Approval

On April 20, 2015, the Delaware Court of Chancery issued a post-trial opinion in the case In Re: El Paso Pipeline Partners L.P. (C.A. No. 7141-VCL), finding El Paso Pipeline GP Company LLC, the general partner (GP) of El Paso...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Tax: HMRC Publishes Filing Dates for New AIFM Mechanism for Partnership Deferred Remuneration Arrangements - The Finance Act 2014 introduced a provision intended to help partnerships (including LLPs) that are AIFM...more

Guaranteed Payments: the Equivalent of a Salary for LLC Members and Partners

Absent special elections to be taxed differently, partnerships and limited liability companies (referred to herein as “entities”) with two or more partners or members (referred to herein as “owners”) are taxed on a...more

I’ll Know it When I See It: Debt vs. Equity in a Partnership

Of the many financial decisions a business faces in its life cycle, one of the most frequent (and certainly most important) is how best to fuel continued growth: should the business issue new debt or new equity? ...more

Partner Liability: Out of the Woods?

Debbett Runnup Partnership, a Texas general partnership, was sued by Widgets R Us in 2010 for failing to pay Widgets R Us invoices. Judgment was granted to Widgets in 2012 against Debbett Runnup for $300,000. After chasing...more

Article Abstract – Preferred Interest Partnerships to Use DSUE Amounts Received by a Surviving Spouse

These abstracts are provided as a service to the readers of Rubin on Tax to advise them of articles that may be of interest to them, both as they are published and as a research tool...more

Recent U.S. Tax Developments Affecting Publicly Traded Partnerships

Partnerships targeted to widespread investors are a popular investment vehicle and a significant source of funding for oil and gas projects. However, their use is affected by the publicly traded partnership (“PTP”) tax rules....more

Abandon All Hope? If a Partnership, Maybe

Several years ago, many taxpayers faced with underwater partnerships would abandon their partnership interests, thereby triggering an ordinary loss. This ordinary loss was often preferred over the capital loss that would be...more

Law Firm Breakup - What You Need to Know When Dissolving the Entity

Law firm ‘partnerships,’ like other businesses, are similar to a marriage; at some point the parties may decide to part ways and dissolve their partnership. Among the many reasons for the dissolution of a law firm are...more

IRS Resumes Publicly Traded Partnership PLRs – New Formal Guidance Expected

The IRS announced that it has made significant progress on its  publicly traded partnership (“PTP”) guidance and is lifting its moratorium on private letter rulings that started in 2014. ...more

Should You Abandon An Underperforming Partnership?

Good news for taxpayers who have, or who are considering, abandoning an interest in an underperforming partnership. Earlier this week the Fifth Circuit overturned the Tax Court’s 2013 decision in Pilgrim’s Pride, clearing...more

Abandonment Losses Back on the Table!

Several years ago, many taxpayers faced with underwater partnerships would abandon their partnership interests, thereby triggering an ordinary loss. This ordinary loss was often preferred over the capital loss that would be...more

U.S. Supreme Court Update, March/April 2015

The Supreme Court heard oral arguments in two cases involving state taxation on consecutive days in December. On 12/8/14, the Supreme Court heard oral arguments in Direct Marketing Ass'n v. Brohl, where the Court has...more

California Tax Developments - A Reed Smith Quarterly Update (4th Quarter 2014)

Case Updates - California Supreme Court Accepts Review of Documentary Transfer Tax Case In our last quarterly update, we reported on a controversial opinion recently published by a California Court of Appeal. In 926...more

Locke Lord QuickStudy: The Fate of Partnerships Under President Obama’s 2016 Proposed Budget

On Monday, February 2, President Obama formally released his 2016 budget proposal and, as expected, it contained numerous changes to the Internal Revenue Code. ...more

Great Tax Planning Opportunity

Undoubtedly, right before the end of the year, you were inundated with information about steps you could take as part of the year-end tax planning for your practice. While the end of the year does offer great tax planning...more

IRS Will Not Follow Partner COD Bankruptcy Exception Cases

In a new Action on Decision (AOD 2015-10), the IRS stated that it will not follow the Tax Court’s 2004 Martinez decision, which had allowed a general partner to exclude cancellation of debt (COD) income from a partnership in...more

California Supreme Court to Review Controversial Documentary Transfer Tax Case

The California Court of Appeal recently held, in 926 North Ardmore Avenue v. County of Los Angeles, that a documentary transfer tax is triggered when a transfer of an interest in a business entity that owns real property...more

IRS Hammers Offshore Lending and Underwriting Structure

In a recent Chief Counsel Advice, in an extended analysis the IRS determined that an offshore partnership with a U.S. manager that was engaged in the finance transactions was determined to be engaged in a U.S. trade or...more

Brands weigh benefits, risks of ‘cause-related marketing’

The morning after the last game of the 2014 World Series, Joe Torre got up early, put on a new uniform and flew to New York to get to work. Torre isn’t trying to make a comeback as a manager. The Hall of Famer and World...more

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