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PIP (partners' interests in the partnership) allocations are very commonly used in partnership agreements. For this reason, Investors and managers should understand the basics of PIP allocations and whether and when they...more
Another Mess- Congress has only a few days to avert a “shutdown” of the federal government. It’s not looking good in the House, as Speaker McCarthy has struggled to bring certain members of the majority into line, while...more
Another Change- Last week BDO confirmed that it was going to convert from an entity organized as a limited liability partnership under state law to one organized as a corporation. With that, BDO became the latest in a...more
1 TYPES OF BUSINESS ENTITIES - There are several forms of business entities in Denmark and there are a wide range of possibilities for establishing a business entity in Denmark. The most suitable entity depends on a...more
July 30, 2020 The operating agreement is the governing document with respect to the management and conduct of a limited liability company (an “LLC”). It outlines the financial and functional decisions of the business and,...more
1. TYPES OF BUSINESS ENTITIES - There are several forms of business entities in Denmark and there are a wide range of possibilities for establishing a business entity in Denmark. The most suitable entity depends on a...more
On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-29, "Guidance Regarding the Implementation of New Section 1446(f) for Partnership Interests That Are Not Publicly...more
Investment Adviser AXA Wins Excessive Fee Trial - A federal judge in New Jersey has ruled in favor of AXA Equitable Life Insurance Company (AXA Equitable) and its wholly owned subsidiary, AXA Equitable Funds Management...more
Key Points - - Final, temporary and proposed regulations issued on October 5, 2016, address complex rules dealing with partnership disguised sales and debt allocation rules under Sections 707 and 752 of the Internal...more
On October 5, 2016, the Treasury Department and Internal Revenue Service (“IRS”) published much-anticipated final, temporary and new proposed regulations providing guidance under Internal Revenue Code sections 707 and 752 on...more
If a partner contributes property to a partnership, and within a two year period, receives cash from that partnership, the tax rules generally treat that as a disguised sale of property by the partner to the partnership. ...more
On August 3, 2015, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations under Section 706(d), providing rules for determining the partners’ distributive shares of...more
I’m at the ABA Tax conference this week and one of this morning’s first panels included a discussion of hot topics in partnerships. Curtis Wilson, IRS Associate Chief Counsel in Passthroughs and Special Industries,...more
On July 22, 2015, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released proposed regulations under Section 707(a)(2)(A) (the proposed regulations) which would treat certain partnership...more