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Internal Revenue Code (IRC) U.S. Treasury Related Parties

Allen Matkins

Final Regulations Released for Partnership Recourse Liabilities

Allen Matkins on

On December 2, 2024, the Department of Treasury published final regulations (Final Regulations) governing the allocation of recourse liabilities of a partnership among its partners under Section 752 of the Internal Revenue...more

Williams Mullen

IRS Releases Finalized Regulations Regarding Taxation of Carried Interest

Williams Mullen on

The U.S. Department of Treasury and the Internal Revenue Service recently issued final regulations (“the Final Regulations”) regarding certain aspects of so-called carried interest under Section 1061 of the Internal Revenue...more

Eversheds Sutherland (US) LLP

Only the Lonely: “Lonely” Life Insurance Companies Confront New Issues Under Proposed Debt-Equity Regulations

The rules of IRC § 1504 and Treas. Reg. § 1.1502-47 provide the general parameters for determining whether a domestic life insurance company (within the meaning of IRC § 816(a)) may join in filing a consolidated U.S. federal...more

Eversheds Sutherland (US) LLP

State Tax Fallout From Federal Proposed Related-Party Debt Regulations

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more

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