Summary -
On November 28, the Tax Court, granting the Internal Revenue Service (IRS) summary judgment, held in Soroban Capital Partners LP v. Commissioner that a state law limited partner who is limited in name only, is...more
Introduction and Background -
Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more
8/17/2020
/ Capital Gains ,
Carried Interest ,
Economic Substance Doctrine ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Real Estate Investments ,
REIT ,
Reporting Requirements ,
RICs ,
S-Corporation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
In Notice 2020-23, released on April 9, the Department of the Treasury expanded the relief offered in earlier notices to apply to a broader set of taxpayers, additional tax returns and tax payments required to be filed or...more
In Notice 2020-18, released on March 25, the Department of the Treasury announced that any person with a federal income tax payment or federal income tax return due on April 15, 2020 has until July 15, 2020 to make the...more
March 20 Update -
Secretary Mnuchin tweeted that the Department of the Treasury will be moving “Tax Day from April 15 to July 15 this year.” When the official Treasury Notice is released, we will update this document with...more
Last week, President Trump signed H.R. 1 (New Act), the new tax bill amending the Internal Revenue Code to reduce tax rates, modify policies, credits, and deductions for individuals and businesses “to provide for...more
Section 385 Proposed Regulations — Impact on Related-Party Financing -
Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more
12/13/2016
/ Audits ,
Bifurcation ,
Change of Ownership ,
Debt ,
Debt Instruments ,
Device Test ,
Equity ,
Expanded Group Instruments (EGIs) ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Net Operating Losses ,
Partnerships ,
REIT ,
Revenue Procedure 2016-40 ,
Safe Harbors ,
Section 355 ,
Section 385 ,
Stocks ,
Tax-Free Spin-Offs
CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes.
Do you have responsibility, whether direct or dotted line, for the tax function in your...more
In this Presentation:
- Topics
- Inversion
- Inversions – How Did We Get Here?
- Impact Of The §367 Regulations
- 2003 – Enactment of §7874
- §7874
- Determining “Ownership”
- Treasury Regulation...more