Section 1402(a)(13) of the Internal Revenue Code provides that the distributive share of “limited partners, as such” from a partnership is not subject to self-employment tax.[1] Managers of private equity and hedge funds are...more
On April 23, the Treasury Department and the Internal Revenue Service (the "IRS") issued helpful proposed regulations under section 512(a)(6) of the Internal Revenue Code (the "proposed regulations"). Section 512(a)(6) was...more
On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more
11/2/2016
/ Acquisitions ,
Bifurcation ,
Corporate Taxes ,
De Minimus Quantity Exemption ,
Debt Instruments ,
Debt-Equity ,
Disregarded Entities ,
Distribution Rules ,
Expanded Group Instruments (EGIs) ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
S-Corporation ,
Section 385 ,
Securities ,
Stocks
On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385. The final and temporary regulations recharacterize certain debt instruments as equity for...more
10/27/2016
/ Asset Stripping ,
Bifurcation ,
Debt ,
Debt Instruments ,
Disregarded Entities ,
Equity ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Publicly-Traded Companies ,
Section 385 ,
Securities ,
Stocks ,
U.S. Treasury
On July 15, 2016, the U.S. Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) published proposed regulations that would modify the device and active trade or business requirements for tax-free...more
7/29/2016
/ Active Trade or Business Test ,
Device Test ,
Grandfathering Rules ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Section 355 ,
Shareholders ,
Spinoffs ,
Tax Avoidance ,
Tax-Free Transfers ,
U.S. Treasury ,
Yahoo!