The IRS and Treasury issued new guidance that supersedes earlier guidance relating to the postponement of the April 15, 2020 tax deadline due to the COVID-19 pandemic.
On Friday, the IRS and Treasury announced that both the...more
In the early 1990s, Congress enacted the qualified small business stock (“QSBS”) rules to incentivize equity investments in certain corporations. The QSBS rules reduce the effective federal income tax rate on the gain...more
The recent Bipartisan Budget Act of 2015 (the “Act”) sets forth a new tax audit regime for partnerships (and limited liability companies taxed as partnerships) that will have far-reaching consequences. The new audit...more
On July 22, 2015, the IRS released proposed regulations that could limit the utility of “management fee waiver” arrangements (the “Proposed Regulations”). Management fees generally are taxable as compensation income....more
7/31/2015
/ Capital Gains ,
Clawbacks ,
Deferred Compensation ,
Fee Waivers ,
Fund Sponsors ,
Internal Revenue Code (IRC) ,
IRS ,
Management Fees ,
Partnership Agreements ,
Partnerships ,
Profits Interests ,
Significant Entrepreneurial Risk (SER)
On March 4, 2014, President Obama issued his Administration’s Fiscal Year 2015 Budget, which includes a proposal to tax carried interests (also known as “performance allocations” or “incentive allocations”) in investment...more
In January 2013, Congress enacted legislation that could provide certain investors who acquire qualified small business stock (“QSBS”) before the end of 2013 with a significant tax benefit. In effect, the gains realized from...more
On September 27, 2013, Massachusetts Governor Deval Patrick signed legislation to retroactively repeal the recent extension of the 6.25 percent Massachusetts sales and use tax to certain types of computer system design and...more
In light of last week’s news that Massachusetts lawmakers intend to retroactively repeal the controversial “tech tax”, the Massachusetts Department of Revenue (“MDOR”) yesterday announced that it is deferring the September 20...more
On September 12, 2013, Massachusetts legislators announced their intention to repeal (with retroactive effect) the recent expansion of the 6.25 percent Massachusetts sales and use tax to certain types of previously untaxed...more
Effective as of July 31, 2013, the Massachusetts 6.25% sales and use tax has been expanded to apply to certain types of computer system design and software modification services (“Computer/Software Services”)....more