Last week the IRS issued a revenue ruling, FAQs, and a revision to draft Schedule 1 to Form 1040 regarding various aspects of virtual currency transactions. The guidance is in line with the Treasury 2019-2020 Priority...more
On November 29, 2017, the U.S. District Court for the Northern District of California dealt a partial blow to the U.S. Department of Justice and the IRS in connection with their collective efforts to enforce an expansive and...more
Last week, on October 2, 2017, the U.S. Department of the Treasury (the “Treasury”) delivered a report to President Trump that proposes substantial revisions to eight sets of controversial U.S. federal income tax regulations...more
The new rules represent a complete overhaul of partnership audit, assessment, and collection procedures. Taxpayers should review and potentially amend partnership agreements before the new rules are scheduled to take effect...more
6/21/2017
/ Audits ,
Bipartisan Budget Act ,
IRS ,
Limited Liability Company (LLC) ,
Local Taxes ,
Partnerships ,
Proposed Regulation ,
Regulatory Freeze ,
TEFRA ,
Trump Administration ,
UPREITS
On October 13th, the Internal Revenue Service (“IRS”) followed through on its promise to issue final regulations and temporary regulations under Section1 385 (the “Final Regulations” and “Temporary Regulations,” respectively)...more
10/24/2016
/ Credit Agreements ,
Creditors ,
Debt Instruments ,
Debt-Equity ,
Debtor-Creditor ,
Disregarded Entities ,
Enforcement ,
Expanded Group Instruments (EGIs) ,
IRS ,
Proposed Regulation ,
Rebuttable Presumptions