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The IRS has issued new guidance to prevent related parties from using partnerships to achieve tax benefits through basis-shifting among assets. The IRS recently released a guidance package aimed at preventing...more
On June 17, 2024, the IRS announced the formation of a dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, which is expected to work with a new “passthrough working...more
Limited liability companies (LLCs) offer significant tax flexibility – for one thing they can elect to be treated as disregarded entities, partnerships, C corporations, or S corporations, and can even shift between those tax...more
In recent years, the utilization of Section 1202 has grown considerably. Many businesses are formed as corporations at conception, private equity investors calculate the tax benefits from Section 1202 into their ROI...more
On July 16, 2021, Governor Baker approved a $47.6 billion fiscal 2022 budget, but sent back a provision the Massachusetts Legislature passed creating a workaround for the federal cap on the state and local tax deduction. ...more
Illinois lawmakers have approved legislation that is both good news and bad news for Illinois taxpayers. The good news is that, if approved by Gov. Pritzker, Illinois taxpayers will be able to take advantage of a workaround...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 14 – October 18, 2019. October 15, 2019: The IRS published a news release that...more
On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more
• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more
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
Good news for taxpayers who have, or who are considering, abandoning an interest in an underperforming partnership. Earlier this week the Fifth Circuit overturned the Tax Court’s 2013 decision in Pilgrim’s Pride, clearing...more
Several years ago, many taxpayers faced with underwater partnerships would abandon their partnership interests, thereby triggering an ordinary loss. This ordinary loss was often preferred over the capital loss that would be...more
Interest-Charge Domestic International Sales Corporations (“IC-DISCs”) offer significant potential tax benefits for U.S. companies that export U.S. manufactured products or certain engineering or architectural services with...more