News & Analysis as of

Pass-Through Entities New Guidance

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

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The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

Farella Braun + Martel LLP

The IRS Is Targeting Partnership Transactions: Is Your Representative Ready?

Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more

Williams Mullen

The Virginia Department of Tax Publishes Pass-Through Entity Tax FAQs

Williams Mullen on

The Virginia Department of Taxation (Department) recently published Virginia Pass-Through Entity Tax Frequently Asked Questions for Taxable Years 2022 and After (FAQs). As summarized below, the FAQs provide helpful guidance...more

Williams Mullen

Virginia Releases Draft Guidelines for Pass-through Entity Tax Elections

Williams Mullen on

On October 31, 2022, the Virginia Department of Taxation (the “Department”) released draft guidance (the “Draft Guidelines”) on Virginia’s elective pass-through entity (PTE) tax, addressing how to make a PTE tax election for...more

Williams Mullen

Virginia Department of Taxation Releases Initial Guidance on New Pass-Through Entity Election, Including Important Details for...

Williams Mullen on

During the 2022 General Assembly Session, legislation was enacted that allows a qualifying pass-through entity (PTE) to make an annual election for Taxable Years 2021 through 2025 to pay income tax at a rate of 5.75% at the...more

Eversheds Sutherland (US) LLP

Department of Taxation and Finance releases long awaited guidance addressing pass-through entity tax

On August 25, 2021, the New York State Department of Taxation and Finance released guidance (Technical Memorandum, TSB-M-21(1)C, (1)I) addressing the recently enacted optional pass-through entity tax (PTET) that partnerships...more

Health Care Compliance Association (HCCA)

Revised UG Ups Micro-Purchase Level, Eases Award Termination, Addresses Indirect Rates

Report on Research Compliance 17, no. 12 (December 2020) - The 120-day closeout that institutions fought for after the Office of Management and Budget (OMB) first released the Uniform Administrative Requirements, Cost...more

Bradley Arant Boult Cummings LLP

Treasury Department Issues Final Regulations Limiting Charitable Deductions – Potential Impact on Alabama Donors? - SALT Alert:...

Now that the dust has settled following the issuance of the final “SALT cap workaround” regulations by the Treasury Department, here’s a summary of those regulations, the IRS guidance issued in connection with the final...more

Holland & Knight LLP

New Treasury Regulations Revise Taxation of U.S. Persons Owning Foreign Corporations - Guidance Will Impact Minority Partners in...

Holland & Knight LLP on

Highlights - • In an unanticipated development, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently issued regulations (New Guidance) that significantly modifies the taxation of U.S....more

Ballard Spahr LLP

Update on Qualified Opportunity Zones: Second Set of Guidance Issued

Ballard Spahr LLP on

OVERVIEW OF QUALIFIED OPPORTUNITY ZONE PROGRAM - The Qualified Opportunity Zone (QOZ) program, introduced in 2017’s Tax Cuts and Jobs Act, is a new incentive program for investments in over 8,700 QOZs located in all 50...more

Burr & Forman

IRS Issues Final Regulations On New Section 199a 20% Profit Deduction For Pass-Thru Businesses, And Also Adds Additional Proposed...

Burr & Forman on

On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly...more

Fenwick & West LLP

IRS Notice 2018-26: Important New Guidance on the Mandatory Repatriation Tax

Fenwick & West LLP on

This document discusses Notice 2018-26, the third IRS Notice providing guidance on the new mandatory repatriation tax under § 965. Most importantly, the Notice sets forth extensive anti-avoidance rules in respect of...more

Miles & Stockbridge P.C.

New Filing Guidance for PTEs Participating in Rehabilitation Credit Projects

In CCA 201641022 (October 7, 2016) (the “CCA”), the IRS issued new guidance regarding filing requirements for pass-through entities (“PTEs”) involved in rehabilitation credit projects. Under this new guidance, (1) a PTE may...more

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