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Seward & Kissel LLP

Private Equity Investment into NFL Teams: Tax and Business Considerations

Seward & Kissel LLP on

Owning an NFL team is no longer a fantasy. The National Football League (the “NFL” or the “League”) voted to allow minority stakes to be sold to private equity firms (“PE”). However, according to NFL.com, “an executive from...more

Cadwalader, Wickersham & Taft LLP

IRS Aims to End Abusive Basis-Shifting Transactions

The IRS has issued new guidance to prevent related parties from using partnerships to achieve tax benefits through basis-shifting among assets. The IRS recently released a guidance package aimed at preventing...more

Proskauer - Tax Talks

Treasury and IRS Announce New Attack on Partnership Basis-Shifting Structures and Establishment of “Passthrough Working Group” to...

Proskauer - Tax Talks on

On June 17, 2024, the IRS announced the formation of a dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, which is expected to work with a new “passthrough working...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Ramps Up Audits on Corporate Aircraft Use for High-Net-Worth Individuals and Affiliated Entities

The Internal Revenue Service (IRS) is increasing audits on corporate aircraft use for high-net-worth individuals, large corporations and complex partnerships as part of its new initiative using Inflation Reduction Act funding...more

Pillsbury - Propel

How This Multimillion-Dollar Tax Benefit Can Slip Through Your Fingers: Don’t Miss Out!

Pillsbury - Propel on

The Qualified Small Business Stock (QSBS) status under Section 1202 of the Internal Revenue Code provides a significant tax advantage for small business owners (i.e., Founders) and investors. It allows for a 100% capital gain...more

Hinckley Allen

Converting an LLC to an S Corporation: A Mistake Waiting to Happen

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Limited liability companies (LLCs) offer significant tax flexibility – for one thing they can elect to be treated as disregarded entities, partnerships, C corporations, or S corporations, and can even shift between those tax...more

Rivkin Radler LLP

Activities Contrary to Public Policy – Revoking the Tax Exempt Status of Universities

Rivkin Radler LLP on

It appears that many of the country’s colleges and universities believe they have not already contributed enough to the decline of American education and to the erosion of our society, generally. These institutions of...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Gray Reed

IRS Takes Warning Shot at Section 643(b) Trust Arrangements

Gray Reed on

For some time, promoters have shopped around an arrangement known as a “section 643(b) trust,” known alternatively as a “non-grantor, irrevocable, complex, discretionary, spendthrift trust.”  On August 9, 2023, IRS Chief...more

Morrison & Foerster LLP

Protecting Tax Assets – Considering an NOL Rights Plan - UPDATED

A corporation’s net operating losses (NOLs)are important assets that can be used to reduce future taxable income. But certain changes in a corporation’s ownership can significantly reduce the value of those NOLs....more

Burr & Forman

Section 139 Helps Employers Help Employees After Hurricane Ian

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We have heard from several clients asking about ways to help their employees that suffered tremendously from the wrath of Hurricane Ian. While there are a variety of Federal, State and private relief efforts underway,...more

McDermott Will & Emery

Huge Win for Refined Coal: DC Appeals Court Permits Tax Credits

McDermott Will & Emery on

On August 5, 2022, the US Court of Appeals for the District of Columbia Circuit upheld the US Tax Court’s bench opinion in favor of partners and investors in a refined coal business. The Internal Revenue Service (IRS) has...more

McDermott Will & Emery

Carbon Capture, Utilization and Sequestration Tax Benefits Under the Proposed Inflation Reduction Act

On July 27, 2022, Senate Majority Leader Chuck Schumer (D-NY) and Senator and Energy and Natural Resources Chair Joe Manchin (D-WV) announced an agreement on a proposed reconciliation package called the Inflation Reduction...more

McDermott Will & Emery

The Working Capital Safe Harbor

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Dickinson Wright

Three Tax Principles that HR Professionals Should Know

Dickinson Wright on

Although it might not be obvious, tax law permeates most HR responsibilities – from paying an employee, to arranging for benefit coverages, to settling employment lawsuits, and paying pensions.  Knowing a few key tax...more

Bilzin Sumberg

What Makes a Trust a "Foreign" Trust?

Bilzin Sumberg on

In a previous post, we discussed the tax implications for U.S. beneficiaries who receive a distribution from a foreign trust. That discussion assumed that the trust in question was, in fact, a foreign trust for U.S. federal...more

Foster Garvey PC

Opportunity Zone Funds – Part IV: The Second Round of Proposed Regulations

Foster Garvey PC on

On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more

Burr & Forman

Senate Finance Committee Probing Conservation Easement Abuse

Burr & Forman on

On March 27, 2019, the Senate Finance Committee launched an investigation into the abuse of syndicated conservation easement transactions. The transactions being investigated involve promoters selling interests in tracts of...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

Holland & Knight LLP

Seven Tips for Tribal Governments to Reduce Tribal Member Taxes in 2019

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• With Democrats taking control of the U.S. House of Representatives, tax provisions affecting tribal governments and their members are once again on the table for discussion. • This notice provides an overview of seven...more

Akin Gump Strauss Hauer & Feld LLP

Opportunity Zones: New Guidance Sheds Light on How Private Equity Industry Can Take Advantage

• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more

Morrison & Foerster LLP

Opportunity Zone Proposed Regulations Issued – Provide Much Needed Clarification and Guidance

Morrison & Foerster LLP on

On October 19, 2018, the U.S. Treasury Department and Internal Revenue Service (“IRS”) issued long-awaited and much anticipated proposed regulations (the “Proposed Regulations”) relating to the Opportunity Zone Fund (“OZ...more

Akin Gump Strauss Hauer & Feld LLP

Opportunity Zones: How Communities Can Leverage This New Provision to Jumpstart Investment

• Even though practitioners are awaiting proposed regulations on the new opportunity zone provision, interested parties are already starting to set up qualified opportunity funds to pool investor capital. • States, cities,...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part VIII: Charitable and Tax-Exempt Organizations / Estate and Gift Taxes

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Charitable organizations work hard to maintain exempt status. These organizations operate in a highly regulated landscape: In exchange for enjoying freedom from income taxes, they must comply with strict organizational and...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part VI: Employment and Fringe Benefit Related Provisions

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BACKGROUND - The Tax Cuts and Jobs Act (“TCJA”) creates, modifies or eliminates a number of employment and employee fringe benefit related provisions of the Code. Both employers and employees need to be aware of these...more

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