On June 17, 2024, the IRS announced the formation of a dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, which is expected to work with a new “passthrough working...more
On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more
6/30/2020
/ Capital Gains ,
Corporate Taxes ,
Foreign Tax Credits ,
IRS ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Registered Investment Companies (RICs) ,
REIT ,
Section 199A ,
Tax Cuts and Jobs Act ,
Tax Reform ,
U.S. Treasury
Introduction -
On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section...more
4/30/2019
/ Anti-Abuse Rule ,
Capital Gains ,
Carried Interest ,
Holding Periods ,
Opportunity Zones ,
Original Use ,
Partnerships ,
Preamble ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments ,
REIT ,
Reporting Requirements ,
S-Corporation ,
Safe Harbors ,
Tax Cuts and Jobs Act
On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...more
12/6/2018
/ Anti-Abuse Rule ,
Business Taxes ,
C-Corporation ,
Controlled Foreign Corporations ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
PFIC ,
Proposed Regulation ,
REIT ,
REMIC ,
Tax Deductions ,
Tax Planning ,
U.S. Treasury
On August 8, 2018, the U.S. Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "IRS") issued proposed regulations regarding the "pass-through deduction" for qualified trade or business income...more
UPDATE: The Senate Finance Committee last night released a revised version of the Chairman’s Mark of the Tax Cuts and Jobs Act. We are reviewing these changes and will release an update soon...
On Thursday, November 9, the...more
11/15/2017
/ 401k ,
403(b) Plans ,
457(b) Plans ,
501(c)(6) ,
Alternative Minimum Tax ,
Capital Gains ,
CFC ,
Charitable Deductions ,
Child Tax Credit ,
Corporate Taxes ,
Cost Recovery ,
DBCF Tax ,
Deferred Compensation ,
Domestic International Sales Corporation ,
EBITDA ,
Employee Benefits ,
FDIC ,
Foreign Corporations ,
GAAP ,
Generation-Skipping Transfer ,
Highly Compensated Employees ,
Independent Contractors ,
Mortgage Interest ,
Partnerships ,
Pass-Through Entities ,
PFIC ,
Section 179 Property ,
Section 199 ,
Section 482 ,
Section 956 ,
Senate Finance Committee ,
Social Security Benefits ,
Sports ,
Tax Exempt Entities ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
UBTI ,
Ways and Means Committee