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Partnerships › Sale of Assets

Fenwick & West LLP

Rawat Creates a Ripple in Statutory Interpretation Principles

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Recently, in Rawat v. Commissioner, the D.C. Circuit reversed the Tax Court decision and held that a foreign partner would not be subject to U.S. tax on selling an interest in a partnership with “hot assets” subject to §...more

Rivkin Radler LLP

An S Corporation’s Sale of Real Property Following the Death of Its Shareholder

Rivkin Radler LLP on

Don’t Do It- There are certain generally accepted “dos and don’ts” of which almost every investor is certainly aware. For example, do not put all your eggs in one basket; if an investment seems too good to be true, stay...more

Rivkin Radler LLP

Selling to Private Equity? Maybe You Should “F Reorg” First

Rivkin Radler LLP on

Having Fun? Hope you had a decent weekend. Perhaps you did something interesting, maybe even fun, like some end-of-season apple picking? Or maybe you had a cider donut with some hot coffee at a farm stand you stumbled upon...more

Nutter McClennen & Fish LLP

Partnership Transactions and Bonus Depreciation: A Narrow Path

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The recently issued bonus depreciation regulations should influence – but not control – how we structure certain partnership contributions and distributions. These transactions include partnership mergers and divisions....more

Latham & Watkins LLP

FCJ Decision Updates Shareholders’ Resolution Requirement for Sale of GmbH Assets

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While a shareholders’ resolution is still required, the FCJ left open the question of whether notarization of the resolution is necessary. The German Federal Court of Justice (FCJ) decided on 8 January 2019 that Section...more

Farrell Fritz, P.C.

Bonus Depreciation: Proposed Regulations And M&A

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Earlier this month, the IRS proposed regulations regarding the additional first-year depreciation deduction that was added to the Code by the Tax Cuts and Jobs Act (“TCJA”). The proposed rules provide guidance that should be...more

Farella Braun + Martel LLP

Tax Cuts and Jobs Act of 2017 Extends Profit Interest Holding Period

Farella Braun + Martel LLP on

The Tax Cuts and Jobs Act imposes a three-year holding period, rather than a one-year holding period, in order to qualify for long-term capital gains rates with respect to profits interests received in connection with the...more

Farrell Fritz, P.C.

Rolling Over Target Equity Into A PE Fund: Part II

Farrell Fritz, P.C. on

Roll-Over: Tax Issue - Picking up on yesterday’s discussion, how can a PEF reconcile its preference to acquire a depreciable or amortizable basis for its target’s assets while, at the same time, affording the target’s...more

Orrick, Herrington & Sutcliffe LLP

Tax Benefit from Leveraged Partnerships Shut Down By New IRS Regulations

Orrick, Herrington & Sutcliffe LLP on

On October 5, 2016, the IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged...more

Gerald Nowotny - Law Office of Gerald R....

For Love or Charity – A Charitable Bailout Using Charitable Remainder Trusts for the Sale of a C Corporation

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I have personally observed in my professional travels that many taxpayers are reluctant charitable donors. However, we you remind a business owner that they only have three choices when it comes to taxes (1) Pay yourself;...more

Williams Mullen

U.S. Tax Court Ruling in State Conservation Tax Credit Case Requires Income Recognition

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In its recently issued opinion in the case of Route 231, LLC v. Commissioner, T.C. Memo 2014-30 (2/24/14), the United States Tax Court (the “Court”) held that a transfer of state tax credits to a 1% member who had contributed...more

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