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A new life for leveraged partnership structures; Treasury and the IRS issue proposed regulations under the disguised sale rules

On June 19, 2018, Treasury and the Internal Revenue Service (IRS) published proposed regulations (REG-131186-17) (2018 Proposed Regulations) concerning the manner in which partnership liabilities are allocated among the...more

Simplified Partnership Audit Procedures Radically Alter the Federal Income Tax Treatment of Partnerships

On November 2, 2015, President Obama signed the Budget Act of 2015 (the “2015 Budget Act”), which makes significant amendments to the procedural rules governing federal income tax audits and judicial proceedings that apply to...more

11/6/2015  /  Audits , Income Taxes , Partnerships , TEFRA

IRS Targets Use of Basket Option Contracts and Basket Contracts by Hedge Funds and Other Taxpayers as Tax Avoidance Transactions

On July 8, the Internal Revenue Service (IRS) issued two notices (Notice 2015-47, 2015-30 IRB 1, and Notice 2015-48, 2015-30 IRB 1) targeting the use of Basket Option Contracts and Basket Contracts as tax avoidance...more

Camp Goes All-In with Comprehensive Tax Plan: Highlights, Tax Reform Status and Impact on Taxpayers

On February 26, Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee, released his much-awaited comprehensive tax reform plan (the “Camp Proposal”). That proposal seeks to cut marginal tax rates...more

A New Way to Unwind (Leveraged Partnership Structures): Treasury and IRS Propose Draconian Changes to the Partnership Liability...

On January 29, Treasury and the IRS issued proposed regulations that would dramatically change the manner in which partnership liabilities are allocated among the partnership’s partners under IRC § 752 (the Proposed...more

2/5/2014  /  IRS , Partnerships , U.S. Treasury
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