News & Analysis as of November 15, 2024

Business Entities

+ Follow

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

For Tax Purposes, Are Limited Partners Really Limited Partners?

Falcon Rappaport & Berkman LLP on 4/17/2024

In Soroban Capital Partners v. Commissioner, the United States Tax Court determined that entities formed as state law limited partnerships did not necessarily mean that the limited partnerships’ limited partners were limited...more

‘As Such’: Soroban Case Puts Limited Partnerships Under Tax Scrutiny

DarrowEverett LLP on 2/14/2024

In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more

Limited in Name but Not in Tax? U.S. Tax Court Increases Tax Liability for Limited Partners

Kohrman Jackson & Krantz LLP on 12/8/2023

Certain limited partners in venture capital and private equity will likely see an increase in their tax liability due to a recent U.S. Tax Court decision. Generally, partners in a partnership and members in a limited...more

Reviewing a Foreign Legal Structure

Freeman Law on 1/25/2023

Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more

IRS Provides More Guidance on “Relevance” and Foreign Entities Making “Check-the-Box Elections”

Bilzin Sumberg on 2/28/2022

In a previous post, we highlighted guidance released by the IRS on the topic of “relevance” and some of the implications it had in the pre-immigration planning context. More specifically, the guidance addressed issues...more

EIN Processing on Hold

Foley Hoag LLP on 4/10/2020

Due to COVID-19 closures at the Internal Revenue Service (IRS), EIN applications that are submitted by telephone, fax or mail currently are not being received or processed. Accordingly, non-U.S. applicants (who generally are...more

Now You See It – Now You Don’t. Like Magic, the City of Portland Disallows Depreciation Deductions Otherwise Allowable as a Result...

Foster Garvey PC on 7/12/2019

Earlier this week, a local tax practitioner asked us whether it was true that the City of Portland no longer allows depreciation deductions resulting from an election under Section 754 of the Internal Revenue Code of 1986, as...more

New Panel, Same Result – Ninth Circuit Upholds Controversial Cost-Sharing Regulations in Altera Case

Orrick, Herrington & Sutcliffe LLP on 6/21/2019

The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more

IRS Aims to Reduce Confusion over Employer Identification Number Applications

Harris Beach PLLC on 3/20/2018

In December, 2017 the Internal Revenue Service (IRS) released a revised Form SS-4, Application for Employer Identification Number and related instructions. An employer identification number (EIN) is a nine-digit number...more

9 Results

View per page

Page: of 1

Income Taxes › Internal Revenue Code (IRC) › Business Entities

"My best business intelligence, in one easy email…"