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Cancellation of indebtedness income: Beware of hidden tax costs in debt modifications

The global COVID-19 pandemic has created financial distress for businesses across the United States, many of which may have been forced to close or otherwise limit their revenue-generating activities. As result, many...more

A new life for leveraged partnership structures; Treasury and the IRS issue proposed regulations under the disguised sale rules

On June 19, 2018, Treasury and the Internal Revenue Service (IRS) published proposed regulations (REG-131186-17) (2018 Proposed Regulations) concerning the manner in which partnership liabilities are allocated among the...more

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