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Partnerships NPRM 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

Proskauer - Tax Talks

IRS Eliminates Signatures on Section 754 Elections, Offering Tax Regulatory Reform Preview (and its Complexity?)

Proskauer - Tax Talks on

In a notice of proposed rulemaking issued on October 11, 2017 (the “NPRM”), the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) proposed an amendment to existing regulations (the...more

Seyfarth Shaw LLP

Proposed Treasury Regulations Offer Guidance on Disguised Payments for Services

Seyfarth Shaw LLP on

Fee waivers by partners for services rendered to their partnerships will now be subject to scrutiny by the Internal Revenue Service (the “IRS”), pursuant to the Treasury Department’s notice of proposed rulemaking (the...more

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