Corporate Taxes, Limited Partnerships, IRS

New Corporate Tax Increase Proposal and Focused IRS Audits - Is the Cost of Business Going Up?

Allen Barron, Inc. on 3/26/2024

The Biden Administration’s new corporate tax increase proposal will face substantial challenges in both branches of Congress this year. The IRS continues to focus on the tax profiles of large corporations, limited...more

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

Akin Gump Strauss Hauer & Feld LLP on 8/27/2021

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

Lawyers on Tap: Tap Tips for Entity Formation and Taxation

Verrill on 5/8/2018

In this episode of Verrill Voices: Lawyers on Tap, Verrill Dana attorneys Jennifer Green and Jonathan Dunitz discuss the importance of entity formation to the overall success of a brewery business, and the differences between...more

Converting a Profits (or Carried) Interest Into a Capital Interest Tax-Free, Even if it is a Marketable Security

Ervin Cohen & Jessup LLP on 7/16/2015

In CCA 201517006 (dated 10/9/14 and released 4/24/15), the general partner of a publicly traded partnership (PTP) had, in addition to its capital interest, a profits interest in the PTP called “incentive distribution rights”...more

Family Limited Partnerships: Are Discounts Disappearing?

Cole Schotz on 7/14/2015

“Family limited partnerships” – that is, family investment entities usually structured as LLCs or limited partnerships – have been a popular estate planning technique for years. Generally speaking, a client can transfer...more

Master Limited Partnerships: Proposed Tax Regulations Scale Back Activities Giving Rise to Qualifying Income

Eversheds Sutherland (US) LLP on 6/25/2015

The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued proposed tax regulations (Proposed Regulations) that provide guidance on, and significantly scale back, the types of activities...more

Publicly Traded Partnership Proposed Regulations

Dechert LLP on 6/24/2015

Widely held partnerships are a significant source of funding for oil, gas and certain natural resources projects, but the publicly traded partnership (“PTP”) rules can cause such partnerships to be treated as corporations for...more

Corporate Taxes › Limited Partnerships › Internal Revenue Service