On October 5, 2016, the Internal Revenue Service (“IRS”) and Treasury Department published final regulations (the "Final Regulations"), temporary regulations (the "Temporary Regulations") and new proposed regulations (the...more
10/25/2016
/ Business Taxes ,
Debt Financing ,
Disguised Sales ,
IRS ,
New Regulations ,
Partnership Agreements ,
Partnership Liabilities ,
Partnerships ,
Proposed Regulation ,
Risk Allocation ,
U.S. Treasury
On November 2, 2015, President Obama signed the Bipartisan Budget Act of 2015 (the “Bill”), which repeals the TEFRA Unified Audit Procedures and replaces them with a radically modified “corporate” model for partnership tax...more