News & Analysis as of

Tax Allocation Agreements Partnerships

New Regulations Dramatically Alter Partnership 'Disguised Sales' and Allocation of Partnership Liabilities

On October 4, 2016, the Internal Revenue Service and the Treasury Department issued a sweeping package of proposed, temporary and final regulations under the Internal Revenue Code that, among other things, significantly...more

DC Circuit Decision Likely to Reignite FERC Debate Over Tax Allowance for Pass-through Entities

by Cozen O'Connor on

The recent decision by the U.S. Court of Appeals for the District of Columbia Circuit in United Airlines Inc., et al., v. Federal Energy Regulatory, Case No. 11-1479, July 1, 2016 (United Airlines) will likely reignite a...more

Status Update on Targeted Allocation Regulations

I’m at the ABA Tax conference this week and one of this morning’s first panels included a discussion of hot topics in partnerships. Curtis Wilson, IRS Associate Chief Counsel in Passthroughs and Special Industries,...more

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