Passive Activity

News & Analysis as of

Master Limited Partnerships: Proposed Tax Regulations Scale Back Activities Giving Rise to Qualifying Income

The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued proposed tax regulations (Proposed Regulations) that provide guidance on, and significantly scale back, the types of activities...more

Publicly Traded Partnership Proposed Regulations

Widely held partnerships are a significant source of funding for oil, gas and certain natural resources projects, but the publicly traded partnership (“PTP”) rules can cause such partnerships to be treated as corporations for...more

IRS Publishes Proposed Regulations for Hedge Fund Reinsurance Arrangements

In April 24’s Federal Register, the IRS released proposed regulations (REG-108214-15) to restrict when a foreign insurance company’s income can be excluded as passive income by giving a more strict definition for the “active...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

SBICs Given Additional Flexibility to Structure Their Investments

Summary - The Small Business Administration (SBA) adopted revisions to its regulations, loosening its prohibition on small business investment companies (SBICs) investing in passive businesses. Under the revised...more

Proposed Anti-Inversion Regulations Would Affect Foreign Insurers

For decades American companies have used so-called “corporate inversions” to lower their tax burdens on foreign-earned income. Typically, the American company is acquired by a foreign company located in a tax-favorable...more

SBIC Client Alert: Changes to Passive Business Rule

Earlier this week, the revised and final “Passive Business Rule” (13 CFR 107.720(b) of the Small Business Investment Act of 1958, as amended) was released by the U.S. Small Business Administration (the “SBA”)...more

Thinking of Moving to Florida? Maybe a Little Further South is a Better Option

In an effort to revitalize its economy, Puerto Rico has passed tax laws intending to attract investment to the island. Located two hours from Florida, the Caribbean territory of the U.S. offers several substantial tax...more

In Frank Aragona Trust, Tax Court Holds that Trustees’ Activities as Employees Count for Purposes of Material Participation Under...

The issue of whether a trust has passive or non-passive income from its investment in a pass-through entity has taken on increased importance in light of the tax imposed on net investment income under Code Section 1411 of the...more

Tax Planning for the Privatization of the Space Industry

The privatization of the space industry has seen dramatic growth in recent years, and it appears that more significant developments are on the horizon....more

High Net Worth Family Tax Report, Vol. 9, No. 1

In This Issue: - Congressman Camp Camp Releases His Long-Awaited Tax Reform Plan - Tax Court Addresses Valuation Issues Related to Tax on Built-In Corporate Gain - Shareholder of S Corporation Required to Include...more

Participation of 100 Hours May Be Sufficient to Generate Active Income Exempt from the 3.8 Percent Health Care Tax on Net...

As business owners begin filing their 2013 federal income tax returns and pay the 3.8 percent tax on net investment income for the first time, they should be aware that 100 hours of participation in an activity may be...more

High Net Worth Family Tax Report, Vol. 8. No. 4 -- December 2013

IRS Explains Federal Tax Consequences of Windsor Case Regarding Same-Sex Marriages - In our last report (Vol. 8, No. 3, September 2013), we told you about the recent Windsor case, in which the Supreme Court held...more

Power Tactics for Dealing with Passive Aggressive People

Be Straight Forward and Stay Assertive - We have all had our bouts with passive aggressive people. You know the kind. Passive aggressors use indirect tactics to needle you and make you downright mad. And then, when you...more

New 3.8% Medicare Tax on Investment and Unearned Income Beginning in 2013

Starting January 1, 2013, a new 3.8% Medicare tax will apply to the investment and “unearned income” of individuals, trusts and estates. The tax is intended to apply to income exempt from the regular FICA or self-employment...more

Estate Planning Update - September 2012: New Taxes Make Year-End Income Tax Planning More Important

It is not too early to start planning income tax steps to take before year-end. The Patient Protection and Affordable Care Act introduced two new taxes that will go into effect January 1, 2013. These are a 3.8 percent...more

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