The U.S. Treasury Department and the Internal Revenue Service (the “IRS”) have re-issued proposed regulations (the “Proposed Regulations”) on the new centralized partnership audit rules enacted as part of the Bipartisan...more
6/22/2017
/ Audits ,
Bipartisan Budget Act ,
Business Taxes ,
C-Corporation ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
S-Corporation ,
TEFRA ,
Trump Administration ,
U.S. Treasury
New rules recently proposed by the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) would re-characterize purported debt instruments as equity instruments, and could have significant implications...more
The Internal Revenue Service (“IRS”) and Treasury Department issued Notice 2014-52 (the “Notice”) targeting corporate inversions on September 22, 2014 (the “Notice Date”) in the U.S. Tax considerations are important for...more