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Partnership Interests Safe Harbors

Rivkin Radler LLP

Indirectly Held Profits Interests and Rev. Proc. 93-27

Rivkin Radler LLP on

At war with Russia in eastern Europe, a nascent competing world order, mass shootings and bank failures at home, questionable audit practices by the Big 4 . . . everywhere, debt ceilings and the risk of default, inflation,...more

Cole Schotz

Starting An Active Business In An Opportunity Zone

Cole Schotz on

This short article outlines the requirements for starting an active business in a qualified opportunity zone (“QOZ”). The US tax legislation that created QOZs was enacted in early 2018, and is intended to encourage...more

Dechert LLP

Newly Proposed Partnership Audit Rules Allow for Multiple-Tier “Push-Out” Election

Dechert LLP on

The U.S. Department of the Treasury (the “Treasury”) and the U.S. Internal Revenue Service (the “IRS”) have issued a new installment of proposed regulations under the centralized partnership audit regime included in the...more

Morrison & Foerster LLP - JOBS Act

Up-C Rule 144 Relief

On November 1, 2016, the SEC issued a no-action letter with respect to the required Rule 144 holding period after the exchange of partnership interests in an umbrella operating partnership (OP units) into shares of its parent...more

Smith Anderson

Taxing LLC Options (It’s Complicated)

Smith Anderson on

Options, warrants, convertible equity and convertible debt are all familiar tools of corporate finance. Taxing LLC Options covers the federal income taxation of non-compensatory options (NCOs) issued by partnerships and LLCs...more

Morrison & Foerster LLP - JOBS Act

SEC Issues Guidance with respect to the Conversion of a REIT’s OP Units

On March 14, 2016, the Staff of the Securities and Exchange Commission (SEC) issued interpretative guidance in response to a request from Bank of America, N.A., Merrill Lynch, Pierce, Fenner & Smith Incorporated with respect...more

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