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DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

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The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

Holland & Knight LLP

Tax Court: IRS Must Adhere to BBA Regulations' Plain Language

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The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more

Stark & Stark

Don’t Let Your LLC Expire: LLC Owners Should Check Formation Documents to Confirm Perpetual Duration

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When the New Jersey Limited Liability Company Act originally went into effect in January 1994, the Internal Revenue Service required that a limited liability company have at least a majority of the characteristics of a...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Corporate Minimum Tax and Stock Repurchase Tax Will Take Effect in 2023, but Questions Remain

The corporate alternative minimum tax (CAMT) and the excise tax on stock repurchases, each enacted as part of the Inflation Reduction Act of 2022, will soon become effective — for the CAMT, for taxable years beginning after...more

Lowenstein Sandler LLP

Inflation Reduction Act Tax Implications

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The President is expected to imminently sign the Inflation Reduction Act of 2022 (the “Act”), which was passed by both the Senate and House of Representatives. This Client Alert addresses two main tax provisions in the...more

Eversheds Sutherland (US) LLP

Three is the magic number of new Paycheck Protection Program guidance from the IRS

The IRS recently released a trio of Revenue Procedures - 2021-48, 2021-49, and 2021-50 - related to the Paycheck Protection Program (PPP), which has been the subject of a number of our previous legal alerts. Some alerts can...more

Rivkin Radler LLP

Not Selling Despite Tax Increases? Review the Buy-Sell Agreement Among Owners

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Not Selling Your Business This Year? Beginning shortly before the House Ways and Means Committee released its version of the President’s Build Back Better plan, several posts on this blog have explored the uptick in M&A...more

Foster Garvey PC

The Oregon SALT Cap Workaround for Pass-Through Entities Is Finally Here – Governor Kate Brown Has Signed Senate Bill 727 Into Law

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Last fall, the IRS announced, with respect to pass-through entities (LLCs or other entities taxed as partnerships or S corporations), that, if state law allows or requires the entity itself to pay state and local taxes (which...more

McDermott Will & Emery

[Webinar] Tax in the City® - November 2nd, 11:30 am - 1:00 pm PDT

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Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape. Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more

McDermott Will & Emery

Weekly IRS Roundup September 20 – 24, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 20 – 24, 2021. September 22, 2021: The US Department of the Treasury (Treasury) and...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposal on Domestic Businesses

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On September 13, 2021, the Congressional House Ways and Means Committee introduced 880 plus pages of legislative tax proposals to help fund the House’s proposed $3.5 trillion stimulus package. Below are tax proposals relevant...more

Akin Gump Strauss Hauer & Feld LLP

Secondary U.S. Withholding for Transfers in Private Investment Funds Delayed Until January 1, 2023

Key Points - Fund-level liability for a buyer’s failure to withhold upon secondary market transfer of an LP interest in a fund with ECI assets will apply only for transfers on or after January 1, 2023. Certain...more

Rivkin Radler LLP

Partners, S Corp. Shareholders And Biden’s 2022 Revenue Proposal: No More Business As Usual

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What A Ride- No one anticipated that the Administration’s proposed tax increases would fly through Congress easily – at least no one residing in a state in which the recreational use of marijuana has not been legalized....more

McDermott Will & Emery

Weekly IRS Roundup November 9 – November 13, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 9, 2020 – November 13, 2020... November 9, 2020: The IRS released Notice 2020-75...more

Ballard Spahr LLP

Carried Interest – Proposed Regulations – Impact on Real Estate: The Good and the Bad

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On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more

Proskauer - Tax Talks

 “Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

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On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more

Miles & Stockbridge P.C.

IRS Extends Tax Deadlines Related to Individuals, Trusts, Estates, Partnerships and Corporations

On April 9, 2020, the IRS issued Notice 2020-23 (the “Notice”), which extends more tax deadlines to cover individuals, estates, corporations and others. The notice expands upon tax relief granted in prior IRS notices that...more

McDermott Will & Emery

Weekly IRS Roundup February 24 – 28, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 24 – 28, 2020. February 24, 2020: The IRS released final instructions to Form 8978,...more

Fenwick & West LLP

PFIC: What U.S. Investment Funds Should be Particularly Aware of and Newly Proposed Regulations

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U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules, which could substantially increase the tax owed on exit for U.S....more

McDermott Will & Emery

Treasury and the IRS Release Final Foreign Tax Credit Regulations

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Final regulations relating to the determination of the foreign tax credit following the Tax Cuts and Jobs Act were released earlier this month. Though largely similar to the proposed regulations, taxpayers may be interested...more

McDermott Will & Emery

Weekly IRS Roundup December 9 – 13, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

A&O Shearman

Final and Proposed TCJA Foreign Tax Credit Regulations Create Traps and Opportunities

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On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

Akin Gump Strauss Hauer & Feld LLP

BBA Tax Audits: Final Deadline for Designating a U.S. Partnership Representative

• U.S. and non-U.S. investment funds that are required to file, or file, a U.S. partnership tax return (Internal Revenue Service (IRS) Form 1065) are generally subject to a new U.S. partnership audit regime that permits the...more

Dechert LLP

IRS Releases Proposed Tax Regulations on PFICs, Including Guidance for Foreign Insurance Corporations and Their Investors

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The U.S. Department of the Treasury and the Internal Revenue Service on July 10, 2019, released proposed regulations relating to the tax treatment of investors that own stock of a passive foreign investment company (“PFIC”)...more

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