News & Analysis as of

Partnerships New Guidance Proposed Regulation

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

DarrowEverett LLP on

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

Holland & Knight LLP

IRS Cracking Down on "Basis-Shifting" in Related-Party Partnership Transactions

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS recently issued guidance aimed at curtailing purportedly abusive basis-shifting transactions utilized by businesses taxed as partnerships. This guidance represents additional...more

Proskauer - Tax Talks

Treasury and IRS Announce New Attack on Partnership Basis-Shifting Structures and Establishment of “Passthrough Working Group” to...

Proskauer - Tax Talks on

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

Proskauer - Tax Talks

Proposed Regulations on UBTI Provide Guidance to Tax-Exempt Organizations Making Fund Investments

Proskauer - Tax Talks on

On April 23, 2020, the Treasury Department and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 512(a)(6) of the Internal Revenue Code (the “Code”). Section...more

Dechert LLP

IRS Releases Proposed Tax Regulations on PFICs, Including Guidance for Foreign Insurance Corporations and Their Investors

Dechert LLP on

The U.S. Department of the Treasury and the Internal Revenue Service on July 10, 2019, released proposed regulations relating to the tax treatment of investors that own stock of a passive foreign investment company (“PFIC”)...more

Sullivan & Worcester

Am I Out-of-Bounds?

Sullivan & Worcester on

Every golfer knows there is a penalty attendant to hitting the ball out-of-bounds. In business, as with golf, being "out-of-bounds" when dealing with the Internal Revenue Code has penal consequences too. But there the analogy...more

Ballard Spahr LLP

Update on Qualified Opportunity Zones: Second Set of Guidance Issued

Ballard Spahr LLP on

OVERVIEW OF QUALIFIED OPPORTUNITY ZONE PROGRAM - The Qualified Opportunity Zone (QOZ) program, introduced in 2017’s Tax Cuts and Jobs Act, is a new incentive program for investments in over 8,700 QOZs located in all 50...more

Poyner Spruill LLP

OZ Update - The New Proposed Regulations Are Out - New Guidance on Eligibility for OZ Tax Benefits

Poyner Spruill LLP on

Last week, Treasury issued a second round of proposed regulations regarding Opportunity Zones?offering investors more clarity as to whether their investments in designated Opportunity Zones will qualify for current capital...more

Sullivan & Worcester

Second Round of Treasury Guidance: Key Provisions

Sullivan & Worcester on

The long-awaited second round of Opportunity Zone-related Proposed Regulations were issued Wednesday, April 17, 2019. It is clear that Treasury’s goals, in its second round of guidance, were to: 1. Provide clarity and/or...more

UB Greensfelder LLP

IRS Issues Long-Awaited Second Round of Opportunity Zone Regulations

UB Greensfelder LLP on

As part of the 2017 Tax Cuts and Jobs Act, Congress added a new provision to the Internal Revenue Code allowing investors to defer capital gains by making investments into Qualified Opportunity Funds (QOFs). However, many...more

A&O Shearman

Opportunity Zones: Second Set of Proposed Regulations Provide Clarity

A&O Shearman on

On Wednesday, April 17, 2019, the Treasury Department and the Internal Revenue Service issued a broad, investment-friendly second set of Proposed Regulations (the “Proposed Regulations”) regarding “Qualified Opportunity...more

King & Spalding

IRS and Treasury Release Second Round of Qualified Opportunity Zone Guidance

King & Spalding on

On April 17th, the IRS and Treasury issued the next (and long-awaited) package of proposed regulations (the “Proposed Regulations”) under the “qualified opportunity zone” provisions of Section 1400Z-2 of the Code...more

Burr & Forman

IRS Issues Final Regulations On New Section 199a 20% Profit Deduction For Pass-Thru Businesses, And Also Adds Additional Proposed...

Burr & Forman on

On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly...more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update

Background – In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income communities designated by the IRS as qualified...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

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