News & Analysis as of

Partnerships New Regulations Internal Revenue Service

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

BakerHostetler

Monetizing Renewable Energy Credits - Final Regulations on Direct Pay

BakerHostetler on

As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable entities...more

Kohrman Jackson & Krantz LLP

Artificial Intelligence Allows IRS to Increase Scrutiny of High-Earners & Partnerships

The Internal Revenue Service (IRS) recently announced a renewed effort to ensure compliance with federal tax law, specifically focusing on high-income earners, partnerships, and large corporations. This additional scrutiny...more

Cadwalader, Wickersham & Taft LLP

Treasury Holds Fast on Centralized Partnership Audits

On December 8, Treasury issued final regulations (the “Final Regulations”) updating the existing centralized partnership audit regime. These regulations largely adopt the provisions of regulations that were previously...more

Goodwin

Highlights From The Final Carried Interest Regulations

Goodwin on

On January 7, 2021, the U.S. Treasury Department and the Internal Revenue Service released final regulations under Section 1061 of the Internal Revenue Code of 1986, as amended (“the Code”). The Final Regulations address the...more

Gould + Ratner LLP

IRS Finalizes Carried Interest Regulations

Gould + Ratner LLP on

The IRS and Treasury Department released final regulations on January 7, 2021, that govern the tax treatment of partnership and LLC interests related to services, so-called carried interests, a/k/a applicable partnership...more

Harris Beach PLLC

IRS Provides Certainty Regarding Deductibility of Connecticut Pass-Through Entity Tax Payments

Harris Beach PLLC on

One of the most controversial individual income tax changes enacted under the Tax Cuts and Jobs Act (“TCJA”) is the $10,000 cap on the deduction for state and local income and property taxes (“SALT”) for federal income tax...more

McDermott Will & Emery

IRS Issues Final Regulations Concerning Withholding on Partnership Interest Transfers

McDermott Will & Emery on

The US Department of the Treasury and Internal Revenue Service (IRS) recently issued final regulations under section 1446(f), a provision enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA) that generally imposes a...more

Vinson & Elkins LLP

[Webinar] All in the Family: Applying the Business Interest Expense Limitation Within Groups - September 30th, 12:00 pm - 1:00 pm...

Vinson & Elkins LLP on

The 2017 Tax Cuts and Jobs Act generally limits the amount of business interest expense that a taxpayer may deduct. This webinar will cover newly issued final and proposed Treasury regulations under section 163(j), with a...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

Ballard Spahr LLP

Partners Must Pay Self-Employment Tax on Partnership Income—Even From a 'Disregarded Entity'

Ballard Spahr LLP on

The IRS has published Final Regulations finalizing its prior guidance that partners in a partnership must pay self-employment tax on their partnership income, even if they work for an entity owned entirely by the partnership...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

Neal, Gerber & Eisenberg LLP

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

Katten Muchin Rosenman LLP

New Partnership Audit Regime Set to Take Effect in 2018, Proactive Planning Recommended

On November 2, 2015, Congress passed the new centralized partnership audit regime as part of the Bipartisan Budget Act of 2015 (BBA) which is set to take effect for the tax years beginning on or after January 1, 2018. The...more

Morrison & Foerster LLP

Recently Issued Final, Temporary and Proposed Treasury Regulations Regarding the Allocation of Partnership Liabilities and...

Morrison & Foerster LLP on

On October 5, 2016, the Internal Revenue Service (“IRS”) and Treasury Department published final regulations (the "Final Regulations"), temporary regulations (the "Temporary Regulations") and new proposed regulations (the...more

Akin Gump Strauss Hauer & Feld LLP

Funds Escape Debt-Equity Regulation Net—For Now

Key Points - - The New Regulations do not apply to debt issued by investment partnership funds, including publicly traded partnership funds, or blockers-at least, not now. - The New Regulations can apply to...more

Bracewell LLP

New Partnership Tax Guidance on Disguised Sales and Liability Allocations

Bracewell LLP on

On October 5, 2016, the Treasury Department and Internal Revenue Service (“IRS”) published much-anticipated final, temporary and new proposed regulations providing guidance under Internal Revenue Code sections 707 and 752 on...more

Miles & Stockbridge P.C.

IRS Clarifies that Indirect Owners of Disregarded Entities Are Liable for Self-Employment Tax

The IRS recently released temporary regulations clarifying that an employee of a disregarded entity is liable for self-employment tax if the employee is a partner in the partnership that owns the disregarded entity. See...more

Proskauer - Tax Talks

New IRS Regulations Subject Certain Partners to Self-Employment Taxes

Proskauer - Tax Talks on

On May 3, 2016, the U.S. Department of the Treasury issued new temporary and proposed regulations (Temp. Treas. Reg § 301.7701-2T) addressing the tax treatment of partners of a partnership that is the sole owner of an entity...more

Sherman & Howard L.L.C.

Employee Benefits Advisory: IRS Issues Rules Clarifying the Self-Employment Tax Treatment of Partners – Possible Impact on...

In new regulations issued on May 4, 2016, the IRS clarified that partners in a partnership (including members of a limited liability company that is taxed as a partnership) that owns a subsidiary that is a disregarded entity...more

Smith Anderson

New Partnership Tax Audit Rules

Smith Anderson on

The Bipartisan Budget Act of 2015 establishes new rules (the “New Partnership Audit Rules”) for the conduct of federal income tax audits of partnerships and the assessment and collection of income taxes resulting from such...more

Ballard Spahr LLP

New Rules Adopted for IRS Partnership Tax Audits

Ballard Spahr LLP on

The Bipartisan Budget Act of 2015 signed by the President Obama on November 2, 2015, creates a new IRS audit regime for all entities treated as partnerships for federal income tax purposes, including partnerships and limited...more

Proskauer Rose LLP

Partnership-Level Tax Under New Audit Rules

Proskauer Rose LLP on

The Bipartisan Budget Act of 2015, signed into law on November 2, 2015, has significantly changed the partnership tax audit rules, effective for tax years beginning after December 31, 2017. Under the current partnership...more

McDermott Will & Emery

Treasury Finalizes Regulations on the Varying Interests Rule Under Section 706

McDermott Will & Emery on

On August 3, 2015, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations under Section 706(d), providing rules for determining the partners’ distributive shares of...more

McDermott Will & Emery

Treasury and IRS Issue New Temporary Treasury Regulations

McDermott Will & Emery on

On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued new temporary Treasury regulations addressing the application of Internal Revenue Code Section 956 to certain...more

26 Results
 / 
View per page
Page: of 2

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

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide