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[Event] Hampton Roads Spring Tax Forum - May 17th, Norfolk, VA

Join our seasoned tax and estate planning attorneys on Wednesday, May 17th in Norfolk for the Williams Mullen Spring Tax Forum. Breakfast will be provided. This program will dig into complex private equity structures, how...more

IRS Releases Finalized Regulations Regarding Taxation of Carried Interest

The U.S. Department of Treasury and the Internal Revenue Service recently issued final regulations (“the Final Regulations”) regarding certain aspects of so-called carried interest under Section 1061 of the Internal Revenue...more

IRS Relief for Partnerships Wanting to Amend Tax Returns

On April 8, 2020, the Internal Revenue Service (IRS) released Revenue Procedure 2020-23 (the Revenue Procedure) allowing eligible partnerships subject to the centralized partnership audit regime (CPAR) to amend 2018 and 2019...more

Pass-through Deductions for Property Owners: New Clarity on Who Qualifies

As part of the 2017 tax overhaul, provisions were put in place that allowed those holding property for rental purposes to write off up to a fifth of their rental income for tax purposes. The deduction was included in Code...more

U.S. Tax Court Ruling in State Conservation Tax Credit Case Requires Income Recognition

In its recently issued opinion in the case of Route 231, LLC v. Commissioner, T.C. Memo 2014-30 (2/24/14), the United States Tax Court (the “Court”) held that a transfer of state tax credits to a 1% member who had contributed...more

New Proposed Regulations Could Shake Up the Allocation of Partnership Debt

The Internal Revenue Service (“IRS”) released proposed regulations changing the analysis of whether a partner bears the economic risk of loss for a partnership liability under IRC Section 752. Also, the proposed regulations...more

Tax Court Ruling Impacts the Treatment of Income Allocations Attributable to Unvested Partnership Capital Interests

The United States Tax Court recently issued its opinion in Crescent Holdings, LLC v. Commissioner, 141 T.C. No. 15 (12/2/13), a ruling regarding allocations of income attributable to an unvested partnership interest. The...more

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