News & Analysis as of September 26, 2024

Internal Revenue Service

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IRS Targeting Partnership Basis-Shifting Transaction Schemes

DarrowEverett LLP on 7/9/2024

The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

Massachusetts Doubles Estate Tax Threshold as Part of $1 Billion Tax Reform Act

Goulston & Storrs PC on 10/5/2023

On October 4, 2023, Massachusetts enacted a new law called “An Act to improve the Commonwealth’s competitiveness, affordability, and equity” (the “Act”). The Act makes several tax law changes relevant to Massachusetts...more

Opportunity Zones: New Guidance Sheds Light on How Private Equity Industry Can Take Advantage

Akin Gump Strauss Hauer & Feld LLP on 10/25/2018

• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more

Tax Reform and Estate Planning: How the 2017 Tax Cuts and Jobs Act Impacts Estate Plans for McNair Clients

Burr & Forman on 10/5/2018

When the 2017 Tax Cuts and Jobs Act was passed, significant changes were made to the Federal Estate, Gift and Generation-Skipping Transfer Tax, the most prominent of which is the increased applicable exclusion amount, which...more

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on 9/18/2018

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

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