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Nutter McClennen & Fish LLP

Partnership Transactions and Bonus Depreciation: A Narrow Path

The recently issued bonus depreciation regulations should influence – but not control – how we structure certain partnership contributions and distributions. These transactions include partnership mergers and divisions....more

Proskauer - Tax Talks

Proposed Regulations on Built-in Gains and Losses under Section 382(h)

Proskauer - Tax Talks on

On September 10, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) on calculation of built-in gains and losses under...more

A&O Shearman

Proposed Section 382 Regulations Would Eliminate Section 338 Approach of Notice 2003-65

A&O Shearman on

On September 9, 2019, the Treasury Department (“Treasury”) and the Internal Revenue Service (the IRS) issued proposed section 382 regulations (REG-125710-18) (the “Proposed Regulations”) reversing certain previously...more

Robins Kaplan LLP

Financial Daily Dose 9.13.2019 | Top Story: ECB Cuts Rates and Restarts QE in Effort to Preempt European Downturn

Robins Kaplan LLP on

The ECB was even more aggressive than expected in its moves to “head off a downturn before it gained momentum,” cutting a key interest rate and reviving “a money-printing program.” At the same time, the central bank “issued...more

Foster Garvey PC

Opportunity Zone Funds – Part III: Lots of Questions But Few Answers

Foster Garvey PC on

There has been a lot of “buzz” in the media about Qualified Opportunity Zones (“QOZs”). Some of the media accounts have been accurate and helpful to taxpayers. Other accounts, however, have been less than fully accurate, and...more

Orrick, Herrington & Sutcliffe LLP

Tax Benefit from Leveraged Partnerships Shut Down By New IRS Regulations

On October 5, 2016, the IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged...more

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