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Fund Managers and Family Offices Get Some Clarity on Carried Interests with Issuance of Proposed Treasury Regulations

On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more

New IRS Deadline for Additional Taxpayers, Plus Relief for Like-Kind Exchanges and Qualified Opportunity Zone Fund Investments

As we reported in our previous client alert, "Federal and State Tax Actions in Response to COVID-19," the IRS has extended until July 15, 2020, the deadline for filing income, gift and GST tax and information returns, and...more

New IRS Rules for Partnership Audits Require Immediate Review of Partnership Agreements

Beginning in 2018, most partnerships (including LLCs and other arrangements treated as partnerships for tax purposes) will be subject to a new “centralized partnership audit regime.” The volume of Internal Revenue Service...more

IRS Issues Guidance to Partnerships Opting-In to New Partnership Audit Regime

The Internal Revenue Service (IRS) issued temporary regulations on August 4, 2016, providing the time, form and manner for partnerships to elect to apply the new partnership audit regime enacted by the Bipartisan Budget Act...more

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