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 May 13, 2019, the U.S. Internal Revenue Service (“IRS”) and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions...more
5/23/2019
/ FIRPTA ,
Foreign Persons ,
Income Taxes ,
International Tax Issues ,
IRS ,
K-1 ,
Partnerships ,
Proposed Regulation ,
Reporting Requirements ,
Shareholders ,
Withholding Requirements
On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more
4/23/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
Tax Reform
On January 18, 2019, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (the “Final Regulations”) regarding the “passthrough deduction” for qualified trade or...more
3/11/2019
/ Business Ownership ,
Final Rules ,
IRS ,
Pass-Through Entities ,
Proposed Regulation ,
Qualified Business Income ,
S-Corporation ,
Section 199A ,
Sole Proprietorship ,
Specified Service Trade Or Business (SSTB) ,
Tax Deductions ,
UBIA
On April 2, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-29 (the “Notice”), announcing the intention of the IRS and the Department of the Treasury to issue regulations regarding the withholding requirements...more
5/9/2018
/ FIRPTA ,
Foreign Investment ,
Income Taxes ,
Interim Guidance ,
International Tax Issues ,
IRS ,
Limited Partnerships ,
Partnership Interests ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Reform ,
Withholding Tax
On December 18, 2015, President Obama signed into law an omnibus appropriations bill which included the Protecting Americans from Tax Hikes Act of 2015 (the "Act"). In addition to extending or making permanent a number of...more
The Bipartisan Budget Act of 2015, signed into law on November 2, 2015, has significantly changed the partnership tax audit rules, effective for tax years beginning after December 31, 2017.
Under the current partnership...more
11/6/2015
/ Audits ,
Bipartisan Budget ,
Burden-Shifting ,
Federal Budget ,
IRS ,
Joint and Several Liability ,
New Legislation ,
New Regulations ,
Partnership Agreements ,
Partnerships ,
Registered Representatives ,
Tax Liability
On July 22, 2015, the U.S. Department of the Treasury and U.S. Internal Revenue Service issued proposed Treasury Regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended, addressing management...more
7/27/2015
/ Capital Gains ,
Deferred Compensation ,
Enterprise Risks ,
Fee Waivers ,
Fund Managers ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Management Fees ,
Private Investment Funds ,
Proposed Regulation ,
U.S. Treasury