News & Analysis as of

Revenue Procedures Financial Services Industry

Proskauer - Tax Talks

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

Proskauer - Tax Talks on

On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more

White and Williams LLP

Taxation of Carried Interests: 2017 Tax Act and Supplemental Guidance

White and Williams LLP on

The ability of a partnership to grant service providers (typically key management) an interest in a partnership on a non-taxable basis, with potential long-term capital gain treatment on post-grant appreciation, is unique to...more

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