News & Analysis as of

Safe Harbors Partnerships

McDermott Will & Emery

[Event] Value-Based Care Symposium 2024 - May 16th - 17th, Nashville, TN

WHERE VALUE-BASED CARE MEETS THE BUSINESS OF HEALTHCARE - Join hundreds of c-suite leaders, investors, operators and counsel in the healthcare capital of the United States for a deep dive into the key business and policy...more

Ankura

U.S. DOJ’s New Safe Harbor Policy: Conducting Enhanced M&A Due Diligence

Ankura on

Last month, U.S. Deputy Attorney General Lisa O. Monaco announced a new Safe Harbor Policy for voluntary self-disclosure (the “Policy”) made in connection with merger and acquisition activity. The Policy is intended to bring...more

Cadwalader, Wickersham & Taft LLP

Tax Court Adopts Broad Reading of Profits Interests Safe Harbor

Thirty years after the IRS first acknowledged that taxpayers could receive profits interests for services without immediate tax, the Tax Court has confirmed our long-held belief that the same protection is available for a...more

A&O Shearman

Tax Court Agrees Profits Interest Safe Harbor Should Apply to Tiered Partnership Structure

A&O Shearman on

On May 3, 2023, the Tax Court released a memorandum opinion in ES NPA Holding LLC v. Commissioner holding that the taxpayer’s indirect receipt of a profits interest in a lower-tier partnership qualified as a non-taxable event...more

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

Williams Mullen

[Event] Hampton Roads Spring Tax Forum - May 17th, Norfolk, VA

Williams Mullen on

Join our seasoned tax and estate planning attorneys on Wednesday, May 17th in Norfolk for the Williams Mullen Spring Tax Forum. Breakfast will be provided. This program will dig into complex private equity structures, how...more

Patton Sullivan Brodehl LLP

LLC and Partnership Authority “Safe Harbors”

California’s statutes governing LLCs and general partnerships include “safe harbor” provisions making it easier for third parties to rely on the apparent authority of an LLC’s manager or a partnership’s partner. The statutes...more

Nutter McClennen & Fish LLP

Fintech in Brief: Colorado Establishes Safe Harbor for Fintech Bank Partnership Model

On August 7, 2020, an Assurance of Discontinuance (the “AOD”) was entered into by and among the Colorado Administrator of the Uniform Consumer Credit Code (the “Administrator”); the Colorado Attorney General; Avant of...more

Foley & Lardner LLP

IRS Releases Initial Guidance Regarding Section 45Q Carbon Sequestration Tax Credit

Foley & Lardner LLP on

On February 20, 2020, the IRS issued its first round of guidance regarding the carbon sequestration tax credit found in Section 45Q (the “Section 45Q Credit”) of the Internal Revenue Code of 1986 (as amended, the “Code”) in...more

Holland & Hart LLP

IRS Publishes Guidance on the Carbon Capture Tax Credit

Holland & Hart LLP on

On February 19, 2020, the IRS issued two guidance items concerning the tax credit for carbon oxide sequestration (COS) under section 45Q: Notice 2020-12 and Revenue Procedure 2020-12. The new guidance is very similar to IRS...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Issues Anticipated Guidance on Section 45Q Carbon Capture Credits

Further clarity could help unlock much needed investment for a significant number of delayed projects. - After a two-year delay, the IRS finally issues highly anticipated guidance regarding the carbon capture tax credit...more

McDermott Will & Emery

Weekly IRS Roundup February 17 – 21, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 17 – 21, 2020. February 18, 2020: The IRS issued a revenue ruling providing various...more

Akin Gump Strauss Hauer & Feld LLP

Carbon Capture Tax Credit Gets a Boost From IRS Guidance – A Practical Guide for Investors

The Internal Revenue Service (IRS) has issued the first round of guidance regarding the tax credit for carbon oxide sequestration under Internal Revenue Code Section 45Q. This guidance is divided between two documents:...more

Hutchison PLLC

What is a Profits Interest?

Hutchison PLLC on

Equity compensation can be different in LLCs and corporations. LLCs have the benefit of using a special equity compensation tool called a “profits interest.” Unlike a traditional stock option, which represents a right to...more

McDermott Will & Emery

Weekly IRS Roundup December 9 – 13, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

Williams Mullen

Pass-through Deductions for Property Owners: New Clarity on Who Qualifies

Williams Mullen on

As part of the 2017 tax overhaul, provisions were put in place that allowed those holding property for rental purposes to write off up to a fifth of their rental income for tax purposes. The deduction was included in Code...more

Harris Beach PLLC

Treasury Releases Second Round of Proposed Opportunity Zones Regulations

Harris Beach PLLC on

On April 17, 2019, the Treasury released long-awaited additional regulations and guidance with respect to Section 1400Z-2 of the Internal Revenue Code, concerning the Qualified Opportunity Zones (“QOZs”) Program (the...more

Miles & Stockbridge P.C.

2nd Tranche of OZ Regulations

On April 16, 2019, Treasury issued its second set of proposed regulations (“OZ Regs 2”) regarding Section 14002 of the Internal Revenue Code of 1986, as amended (the “Code”). The OZ Regs 2 are very helpful and answer a...more

Goulston & Storrs PC

Qualified Opportunity Zones: New Proposed Regulations Provide Further Guidance

Goulston & Storrs PC on

The Treasury Department has now released a second round of proposed regulations on the Qualified Opportunity Zone (“QOZ”) provisions under Internal Revenue Code Section 1400Z-2....more

Bracewell LLP

Is the Opportunity Now a Reality? IRS and Treasury Release Second Tranche of Opportunity Zone Regulations

Bracewell LLP on

After months of waiting, the IRS and the Treasury Department have released a second set of proposed regulations (the “Second Tranche”) relating to the opportunity zone provisions enacted as part of the Tax Cuts and Jobs Act...more

Poyner Spruill LLP

OZ Update - The New Proposed Regulations Are Out - New Guidance on Eligibility for OZ Tax Benefits

Poyner Spruill LLP on

Last week, Treasury issued a second round of proposed regulations regarding Opportunity Zones?offering investors more clarity as to whether their investments in designated Opportunity Zones will qualify for current capital...more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update: New Proposed Treasury Regulations (Part I)

In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income communities designated by the IRS as qualified opportunity zones....more

Proskauer - Tax Talks

The Second Set of Proposed Opportunity Zone Regulations

Proskauer - Tax Talks on

Introduction - On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section...more

Flaster Greenberg PC

Guide to the Surprises Lurking in the QOZ Proposed Regulations

Flaster Greenberg PC on

While mid-April is typically associated by most with Tax Day, this year, April 2019, also became the month the highly awaited second round of Qualified Opportunity Zone Proposed Regulations were issued....more

Sullivan & Worcester

Second Round of Treasury Guidance: Key Provisions

Sullivan & Worcester on

The long-awaited second round of Opportunity Zone-related Proposed Regulations were issued Wednesday, April 17, 2019. It is clear that Treasury’s goals, in its second round of guidance, were to: 1. Provide clarity and/or...more

49 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide