News & Analysis as of

Partnerships

Proposed Tax Regulations Address International Aspects of the New Partnership Audit Regime

by Alston & Bird on

We are about to witness an almost unprecedented centralized partnership audit regime that takes full effect for taxable years starting on or after January 1, 2018, as adopted in late 2015 by Section 1101 of the Bipartisan...more

Partnerships and Limited Liability Companies Take Note: Significant Changes in IRS Audit Procedures Take Effect January 1, 2018

by Pullman & Comley, LLC on

Under pre- 2018 rules, when a partnership (which for this Client Alert will include a limited liability company which is taxed as a partnership) was audited by the IRS, one of the partners acted as the “Tax Matters Partner”...more

Senate and House Tax Bills Provide Support For Oil And Gas Industry

by Snell & Wilmer on

The tax reform bills that passed the U.S. Senate and House of Representatives may provide a windfall of potential tax benefits and breaks for some oil and gas infrastructure developers and operators. In addition to...more

Early New Year’s Resolution: Update Partnership and LLC Agreements to Comply with New IRS Audit Rules

In 2015, Congress repealed the complex and heavily criticized Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) partnership-level audit rules which apply to partnerships and most LLCs. The new audit rules, which...more

Bipartisan House Bill Addresses Syndicated Conservation Easement Tax Shelters

by Coblentz Patch Duffy & Bass on

Last week, Representative Mike Kelly (R) of Pennsylvania and Representative Mike Thompson (D) of California introduced the Charitable Conservation Easement Program Integrity Act of 2017 as H.R. 4459. The Act is simple;...more

Currents - Energy Industry Insights - December 2017

WV DEP Waives Clean Water Act Authority Over Atlantic Coast Pipeline - "The West Virginia Department of Environmental Protection waived the state's authority under the federal Clean Water Act to determine if another major...more

Five Things to Know about the Tax Cuts and Jobs Act

Even with the bill still in Conference, here are some things businesses should follow closely. Both House and Senate Bills call for deemed repatriation of accumulated foreign profits at reduced tax rates. ...more

Reminder: The New Partnership Audit Rules Are Effective for Tax Years Beginning January 1, 2018

by Epstein Becker & Green on

The Bipartisan Budget Act of 2015 (“BBA”), enacted on November 2, 2015, provided for sweeping changes to the way partnerships are audited, including the ability of the Internal Revenue Service (“IRS”) to levy U.S. federal...more

Significant Regulatory Innovations for REITs in Belgium

by Jones Day on

The Situation: Belgium's Law of October 22, 2017, modifies the REIT Regime by broadening the scope of REIT activities and relaxing the country's existing regulatory framework for REITs. The Result: The real estate sector...more

Are Your Partnerships Ready for 2018?

While the news is filled with the ongoing tax reform activity in Congress, there is one tax change that is already in place to take effect January 1, 2018 – the repeal and replacement of the tax audit regime for partnerships....more

Do you know which Business Structure to choose when starting a New Business?

by Foodman CPAs & Advisors on

When opening a new business, electing a business structure is an important decision. The business structure elected can affect how much will be paid in entity income taxes, record-keeping requirements, how much personal ...more

Information Reporting For The Foreign-Owned Not-So-Disregarded Disregarded Entity

by Farrell Fritz, P.C. on

As the taxable year ending December 31, 2017 approaches, the thoughts of most people turn to holidays and family gatherings, feasting and celebrations, and reflecting, perhaps, on another year gone-by. Not so for tax...more

Take Heed: Tax Planning Too Good To Be True? It Might Be…And Taxpayers Can Be Penalized

by Fox Rothschild LLP on

We have all heard the old proverb “if it’s too good to be true, then it probably is.” In the tax world, this proverb might as well be referred to as the economic substance doctrine. Generally, taxpayers are free to structure...more

Theradiag Partners with Biogen on Infliximab Monitoring Kits

by Goodwin on

On November 14, 2017, Theradiag, a French company specializing in in vitro diagnostics, announced that it had entered into a partnership agreement with Biogen to provide LISA TRACKER kits for monitoring Flixabi®, Biogen’s...more

Tax Audit Risk Shifted from Partners to Partnership

by King, Krebs & Jurgens, PLLC on

NEW TAX PARTNERSHIP AUDIT PROCEDURES - A legislative change to partnership tax audit procedures enacted under the Obama administration is set to go into effect as of January 1, 2018. All tax partnerships need to be...more

Considerations for Asian Fund Managers under the U.S. New Partnership Audit Regime

The Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, resulted in a fundamental change in the way the U.S. Internal Revenue Service (IRS) will conduct audits of collective...more

Federal Income Tax Alert - BIG Changes in IRS Partnership Tax Audit Rules Coming in 2018

by GableGotwals on

Changes in federal tax law taking effect in 2018 will change procedure and shift liability for federal income tax determined to be due in Internal Revenue Service (“IRS”) audits of partnerships. Partnership agreements,...more

The risk of uncertain partnership arrangements

by Dentons on

The risks for partnerships operating without a written partnership agreement in place are well known. A recent Court of Appeal case is a useful reminder that these risks can arise in the period after new partners join a...more

Private Equity and Other Carried Interest Funds – Federal Tax Policy Tip Sheet: Issue 4

by Holland & Knight LLP on

The House of Representatives on Nov. 16, 2017, voted on and passed their tax reform bill, along party lines (227-205). Passage was expected in the House, where the GOP hold a significant enough majority needed to move the...more

Nate Smithson Provides an Update on Tax Reform

by Jackson Walker on

Jackson Walker partner Nate Smithson has prepared an updated guide to tax reform which reflects the senate’s newly-proposed tax bill. The guide covers tax brackets, deductions, capital gains, and other relevant topics in tax...more

The Senate Finance Committee’s proposal for tax reform, and how it compares with the bill passed by the House Committee on Ways &...

by Proskauer - Tax Talks on

UPDATE: The Senate Finance Committee last night released a revised version of the Chairman’s Mark of the Tax Cuts and Jobs Act. We are reviewing these changes and will release an update soon... On Thursday, November 9, the...more

Bad Blood Among Late Developer’s Heirs Jeopardizes Real Estate Mega-Deal

A New York real estate deal valued at close to $1 billion came to a grinding halt when the underlying animosities between a late developer’s widow and his children from previous marriages came to a head in court. Although the...more

The Impact On U.S. Corporations If The House's "Tax Cuts And Jobs Act" Passes

We drafted a tax alert that addresses the impact of the much anticipated "Tax Cut and Jobs Act" (H.R. 1) on the taxation of U.S. Corporations. The complete text of the alert is available here. Below is a brief summary of H.R....more

LLC-To-Partnership Conversion: There’s More To It Than Meets The Eye

by Farrell Fritz, P.C. on

Some Days Are Stones[1]- It’s not always easy to find a topic about which to write a weekly blog post. I usually look for a ruling or decision that illustrates one of the recurring themes of the tax law, and then develop a...more

House Bill Proposes Major Modifications To Employee Compensation And Benefits-Related Laws; Initial Amendments Provide Limited...

by Katten Muchin Rosenman LLP on

The Tax Cuts and Jobs Act proposed by the US House of Representatives on November 2 (House Bill) proposes major modifications to employee and partner compensation and benefits-related provisions of the Internal Revenue Code,...more

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