The formation of a partnership is generally a nonrecognition transaction for both the contributing partner and the newly created firm. Thus, no gain is recognized to a partnership or to any of its partners because of a...more
On October 16, 2018, the Internal Revenue Service (IRS) released Rev. Proc. 2018-54, which addresses the treatment of a new mortgage-backed security under the diversification rules of IRC § 817(h). This new security, called a...more
The IRS recently provided relief from the RIC distribution requirement for money market funds that receive contributions in connection with the transition to a floating NAV, enabling RICs to top up their NAVs without having...more