The ongoing COVID-19 pandemic has caused many individuals to reevaluate vacation destinations and where they choose to work. Why work in snowy Chicago during the winter months when you can perform the same work remotely in a...more
On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more
8/25/2020
/ Arms Length Transactions ,
Capital Gains ,
Capital Investments ,
Carried Interest ,
Fund Managers ,
Holding Periods ,
Income Taxes ,
Investment Adviser ,
Investment Management ,
IRS ,
Partnership Interests ,
Partnerships ,
Pass-Through Entities ,
Popular ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
As we reported in our previous client alert, "Federal and State Tax Actions in Response to COVID-19," the IRS has extended until July 15, 2020, the deadline for filing income, gift and GST tax and information returns, and...more
We believe the following tax developments are of particular interest to our clients.
Tax Return Filing Extensions -
The 2019 federal income tax return filing deadline is extended to July 15, 2020, for individuals,...more
4/1/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Federal Loans ,
Financial Stimulus ,
Net Operating Losses ,
Paycheck Protection Program (PPP) ,
Relief Measures ,
SBA ,
SBA Lending Programs ,
Small Business ,
Tax Relief
Historically, we have advised clients that it is no less advantageous, from a federal income tax perspective, to acquire a partnership interest (including a membership interest in an LLC taxed as a partnership) than it would...more
On June 21, 2018, the United States Supreme Court dramatically altered the state tax world when it issued its decision in South Dakota v. Wayfair, Inc....more
9/25/2018
/ Constitutional Challenges ,
Internet Retailers ,
Interstate Commerce ,
New Guidance ,
Online Sales Tax ,
Out-of-State Companies ,
Physical Presence Test ,
Quill ,
Retail Market ,
Sales & Use Tax ,
Sales Tax ,
SCOTUS ,
South Dakota v. Wayfair ,
State and Local Government ,
State Taxes ,
Substantial Nexus ,
Tax Liability ,
Tax Planning
Beginning in 2018, most partnerships (including LLCs and other arrangements treated as partnerships for tax purposes) will be subject to a new “centralized partnership audit regime.” The volume of Internal Revenue Service...more
It is unheard of for a deal to die at the closing table because lawyers cannot deliver a required opinion regarding a transaction that they structured and negotiated. Yet, this is exactly what happened last year when two...more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published proposed regulations on August 25, 2016 that would require certain private trust companies utilized by high net worth individuals,...more
9/7/2016
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Comment Period ,
Customer Due Diligence (CDD) ,
Customer Identification Program (CIP) ,
Financial Institutions ,
FinCEN ,
High Net-Worth ,
Investors ,
Legal Entities ,
Private Trust Companies
The Internal Revenue Service (IRS) issued temporary regulations on August 4, 2016, providing the time, form and manner for partnerships to elect to apply the new partnership audit regime enacted by the Bipartisan Budget Act...more
The Internal Revenue Service (IRS) released regulations on August 2, 2016 that would limit the use of discounts when valuing interests in family entities for estate, gift and generation-skipping transfer tax purposes. If...more
8/10/2016
/ Bright-Line Rule ,
Business Valuations ,
Closely Held Businesses ,
Estate Tax ,
Family Businesses ,
Generation-Skipping Transfer ,
IRC Section 2704 ,
IRS ,
Limited Liability Company (LLC) ,
Limited Liability Partnerships ,
Transfer Taxes ,
Wealth Management
Every five years, the U.S. Bureau of Economic Analysis of the U.S. Department of Commerce (BEA) conducts a “benchmark” survey regarding U.S. direct investment abroad by country and industry. The purpose of the survey is to...more