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Tax Bill Proposes Trillions in Tax Cuts and Significant Tax Increases

The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions has begun, with House Ways & Means Committee proposals (the Markup) to spend...more

Inflation Reduction Act Expected to Become Law

Key Takeaways: ..The Senate voted 51-50 on August 7 to pass the Inflation Reduction Act. ..The legislation is expected to pass the House this week without changes and to be signed by President Biden. ..The...more

House and Senate Advance President Biden's Far-Reaching 2021 Tax Changes

The House Ways and Means Committee this week released draft legislation advancing various tax change proposals. The House action follows several recent releases by the Senate Finance Committee, including proposals focused on...more

Senate Finance Chair Wyden Proposes Extraordinary Changes to Partnership Tax Rules

On Friday, September 10, 2021, Senate Finance Committee Chairman Ron Wyden released a discussion draft and legislative text that would dramatically change existing partnership tax rules. According to the discussion draft, the...more

9/16/2021  /  IRS , Tax Planning

Carried Interest Update: Final Regulations Provide Taxpayer-Favorable Rules, but Unanswered Questions Linger

On Jan. 19, 2021, the Internal Revenue Service and the Treasury Department published final regulations on the Section 1061 “carried interest” rules (T.D. 9945). The final regulations generally adopt proposed regulations...more

President to Sign Consolidated Appropriations Act that Includes $900 Billion for COVID-19 Relief

On Dec. 21, 2020, Congress passed the Consolidated Appropriations Act, 2021 (CAA), an approximately $2.3 trillion omnibus appropriations bill to fund the government through September of 2021 that includes $900 billion of...more

New Proposed Regulations Turn Off the Centralized Partnership Audit Rules in Certain Cases and Provide Guidance on QSub Partners

On Nov. 20, 2020, the IRS and Treasury Department released proposed regulations on the centralized partnership audit rules enacted as part of the Bipartisan Budget Act of 2015 (the BBA Rules). The proposed regulations allow...more

12/7/2020  /  Audits , Bipartisan Budget , IRS , Partnerships , QSub

Proposed Regulations Provide Guidance on Taxation of Carried Interests

On July 31, the IRS and the Treasury Department released long-awaited proposed regulations on the Section 1061 “carried interest” rules. The proposed regulations include extensive definitional and operational rules on the...more

8/19/2020  /  APIs , Carried Interest , IRS , U.S. Treasury

Administrative Relief: IRS Will Allow Partnerships To File Amended Returns and Real Property Businesses To Undo Interest Expense...

As promised, the IRS has begun to issue guidance assisting taxpayers in applying the retroactive aspects of the CARES Act. To address the disconnect between certain partnerships’ ability to file amended returns and the CARES...more

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