The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) on July 31, 2020 issued long-awaited proposed regulations (the “Proposed Regulations”) providing guidance under section 1061...more
8/13/2020
/ Capital Gains ,
Carried Interest ,
Fund Managers ,
IRS ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
REIT ,
RICs ,
S-Corporation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
In the wake of the Coronavirus pandemic, on March 18, 2020 the U.S. Internal Revenue Service issued guidance extending the Federal income tax payment deadline for any person with a Federal income tax payment otherwise due...more
The Opportunity Zone program created by the Tax Cuts and Jobs Act of 2017 (the “TCJA”) allows taxpayers that realize certain gains to elect to defer the federal income tax on such gains by reinvesting them into Qualified...more
10/24/2018
/ Business Taxes ,
Capital Gains ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning
A recent U.S. Tax Court case, Grecian Magnesite (149 T.C. No. 3, July 13, 2017), has declared invalid the long-standing U.S. government position that a non-U.S. person’s sale of an interest in a partnership (in this case, a...more
7/19/2017
/ Capital Gains ,
Foreign Investment ,
Foreign-Owned Corporations ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Non-Resident Income Taxes ,
Partnership Interests ,
Partnerships ,
Reversal ,
Tax Court ,
Transfer of Interest
The U.S. Treasury Department and the Internal Revenue Service (the “IRS”) have re-issued proposed regulations (the “Proposed Regulations”) on the new centralized partnership audit rules enacted as part of the Bipartisan...more
6/22/2017
/ Audits ,
Bipartisan Budget Act ,
Business Taxes ,
C-Corporation ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
S-Corporation ,
TEFRA ,
Trump Administration ,
U.S. Treasury
New rules recently proposed by the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) would re-characterize purported debt instruments as equity instruments, and could have significant implications...more
There has been buzz in the tax and private equity communities about the rise in audits of private equity firms by the Internal Revenue Service (“IRS”). This has been fueled by the restructuring of the IRS’ Large Business &...more
Congress recently amended the rules governing tax audits of partnerships that file U.S. partnership returns, including U.S. partnerships (and limited liability companies treated as partnerships) and certain non-U.S....more
The Internal Revenue Service (“IRS”) and Treasury Department issued Notice 2014-52 (the “Notice”) targeting corporate inversions on September 22, 2014 (the “Notice Date”) in the U.S. Tax considerations are important for...more