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
The U.S. Department of the Treasury and IRS recently issued guidance aimed at curtailing purportedly abusive basis-shifting transactions utilized by businesses taxed as partnerships. This guidance represents additional...more
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
Effective March 23, 2016, the Treasury Department and Internal Revenue Service published Notice 2016-27, once again extending, until June 30, 2016, the deadline for executors and other persons to complete and file Form 8971...more
Action Item: It is anticipated that Treasury will soon issue new regulations that will affect the valuation discounts applicable to intra-family transfers of interests in closely held entities. It may be advisable to review...more