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On January 10, 2025, the Treasury and IRS issued final regulations identifying certain partnership related party “basis shifting” transactions and substantially similar transactions as transactions of interest (TOIs), which...more
The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more
Knowing who owns legal entities is essential to stopping terrorism, money laundering, and other sophisticated criminal enterprises. For entities formed in the United States there has never been a requirement to disclose...more
On October 9, 2019, the Internal Revenue Service (“IRS”) issued final regulations on the allocation of partnership recourse liabilities that essentially eliminate the use of “bottom dollar” guarantees to increase a partner’s...more
The U. S. Department of Labor’s Conflict of Interest regulatory package (the “COI Rules”) reaches far more than traditional trustees named in retirement plan documents. Many financial advisors, tax advisors, investment...more