The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) announced the latest chapter in the long-trumpeted enforcement initiative aimed at large partnerships. The guidance, summarized below,...more
Large partnerships are facing a sea change in tax enforcement. Beginning with the Large Partnership Compliance program announced in 2021 and its most recent announcement that it intends to “stand up” a group focused on large...more
10/10/2023
/ Artificial Intelligence ,
Audits ,
Enforcement ,
General-Business ,
Hedge Funds ,
Information Document Requests ,
IRS ,
Large Business & International Division (LB&I) ,
Master Limited Partnerships ,
Partnerships ,
Pass-Through Entities ,
Private Equity ,
Real Estate Transactions ,
Tax Litigation
Along with the broader market, real estate investment trusts (“REITs”) and publicly traded partnerships, frequently referred to as master limited partnerships (“MLPs”), have increasingly embraced the principles of...more
9/8/2023
/ Carbon Capture and Sequestration ,
Environmental Social & Governance (ESG) ,
IRS ,
Leases ,
MLPs ,
Partnerships ,
Private Letter Rulings ,
Qualifying Income ,
Real Estate Investments ,
REIT ,
Shareholders ,
Taxable Income
On August 16, 2022, the Inflation Reduction Act of 2022 (the “IRA”) was enacted into law. Among other changes to the Internal Revenue Code of 1986, as amended (the “Code”), the IRA imposes a 15% corporate alternative minimum...more