News & Analysis as of

Partnerships Pass-Through Entities Capital Gains

Whiteford

Client Alert: Update: How "Profits Interest" Works And Why Knowing That Can Matter A Whole Lot

Whiteford on

In many ways, the labor market is as competitive as ever. Businesses continue to explore compensation packages, in addition to ordinary salary, that will help them attract, hire and retain talent. One method of compensation...more

Rivkin Radler LLP

Planning for the Interest Charge on Installment Sales: Decanting a Grantor Trust?

Rivkin Radler LLP on

I recently encountered an interesting situation in which someone suggested that a grantor trust be decanted into a non-grantor trust before the end of the taxable year. The reason? To avoid the special interest charge that...more

Venable LLP

California Nonresidents Selling Partnership Interests Beware: Franchise Tax Board Conflates Federal Gain Recharacterization Rules...

Venable LLP on

​​​​​​​Nonresidents of California generally are not taxed by California on gain resulting from the sale of partnership interests. Under new guidance issued by the California Franchise Tax Board ("FTB") nonresidents can now...more

Rivkin Radler LLP

S Corps with Real Property: Separating Shareholders & Partnership Envy

Rivkin Radler LLP on

Tax Alchemy? How many of you remember Section 138509 of the Ways and Means Committee’s markup last September of what would have been the Build Back Better Act? (A moment of silence, please.) Allow me to jog your memory....more

Jackson Lewis P.C.

Carried Interest/Promote in 2022: Action Items for Investment, Private Equity, Real Estate Fund Managers

Jackson Lewis P.C. on

Investment, private equity, and real estate fund managers should consider becoming familiar with the complex final regulations on the preferential tax treatment of “carried interest” under Section 1061 of the Internal Revenue...more

ArentFox Schiff

One, Two, Three, Four . . . Can I Have a Little More? Another State Enacts SALT Cap Workaround

ArentFox Schiff on

While business owners wait to see whether Congress raises the U.S. long-term capital gains rate from 20 percent to 25 percent and enacts relief from the limitations on the deductibility of state and local taxes (SALT),...more

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

Rivkin Radler LLP on

Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

Farrell Fritz, P.C.

The Loss Of The Favorable Capital Gain Rate, The Exclusion Of Gain under Section 1202, And The Incorporation Of The Partnership

Farrell Fritz, P.C. on

If the Democrats Win- Science has not established – at least to my knowledge – any correlation between the pre-election year-end activities of individual business owners, on the one hand, and election outcomes, on the...more

Neal, Gerber & Eisenberg LLP

Fund Managers and Family Offices Get Some Clarity on Carried Interests with Issuance of Proposed Treasury Regulations

On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more

White & Case LLP

Overview of the Carried Interest Rules and the Proposed Regulations

White & Case LLP on

On July 31, 2020, the U.S. Internal Revenue Service (the "IRS") and the U.S. Treasury Department ("Treasury") issued proposed regulations (the "Proposed Regulations") that provide taxpayers with definitional and computational...more

Dechert LLP

Proposed Carried Interest Regulations: Treasury Carries the Ball, Giving Precious Few Points to Fund Managers

Dechert LLP on

The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) on July 31, 2020 issued long-awaited proposed regulations (the “Proposed Regulations”) providing guidance under section 1061...more

Proskauer Rose LLP

Key Takeaways from the Proposed Regulations on Carried Interest

Proskauer Rose LLP on

On July 31, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) providing guidance on Section 1061 of the Code, as...more

Proskauer - Tax Talks

 “Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

Proskauer - Tax Talks on

On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more

Roetzel & Andress

Roetzel HealthLaw HotSpot: Optimizing Your Practice for Sale

Roetzel & Andress on

Roetzel HealthLaw HotSpot™ is a podcast for physicians and health professionals that covers the legal issues and trends that affect the health care industry. In Episode 4, John Waters discusses the ins and outs of preparing...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

Foster Garvey PC

Opportunity Zone Funds – Part I: Overview of the Law

Foster Garvey PC on

BACKGROUND - Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more

Sullivan & Worcester

Structuring Opportunity Zone Funds

Sullivan & Worcester on

The Opportunity Zones Program created by the U.S. Tax Cut and Jobs Act of 2017 (the "OZone Program") and the first wave of proposed regulations issued by the Treasury Department on October 19, 2018 (the "Regulations") have...more

Burr & Forman

The New Section 199A 20% “Profit Deduction” for Pass-Through Businesses: The Undecided Issue of Owner Compensation

Burr & Forman on

Under the Tax Cuts and Jobs Act, Congress is now offering a new 20% deduction for “pass-through” businesses – i.e. businesses that are not corporations. With the corporate tax rate being reduced under the new law to a flat...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Transportation, Ports and Maritime Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Healthcare Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Proskauer - Tax Talks

The Senate Finance Committee’s proposal for tax reform, and how it compares with the bill passed by the House Committee on Ways &...

Proskauer - Tax Talks on

UPDATE: The Senate Finance Committee last night released a revised version of the Chairman’s Mark of the Tax Cuts and Jobs Act. We are reviewing these changes and will release an update soon... On Thursday, November 9, the...more

Orrick, Herrington & Sutcliffe LLP

The Impact on Taxation of PassThroughs if House Tax Cuts and Jobs Act Passes

On November 2, 2017, the House of Representatives (the "House") introduced the Tax Cuts and Jobs Act ("H.R.1"). This bill, if passed, would make fundamental changes in the taxation of businesses operated in pass-through form....more

Latham & Watkins LLP

US Tax Court Exempts Gain on Sale of a Partnership Interest

Latham & Watkins LLP on

Decision could open planning opportunities for non-US partners regarding sale of a partnership interest. The Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner 1 case — which the US Tax Court decided...more

Jackson Walker

Nate Smithson Provides an Update on Tax Reform

Jackson Walker on

Jackson Walker partner Nate Smithson has prepared an updated guide to tax reform under the Trump administration. The guide covers tax brackets, deductions, capital gains, and other relevant topics in tax law. ...more

24 Results
 / 
View per page
Page: of 1

"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