News & Analysis as of

Partnerships Regulatory Agenda

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

Schwabe, Williamson & Wyatt PC

Department of Treasury Issues Final Regulations Regarding Elective Pay Program ‎

The final regulations are effective on May 10, 2024. ‎ Last week, the Department of the Treasury issued final regulations that address the Elective Pay program (also called direct pay), predominantly under Internal Revenue...more

Cadwalader, Wickersham & Taft LLP

To Elect or Not to Elect: U.S. Partners May Soon Have to Decide for Themselves Whether to File Passive Foreign Investment Company...

U.S. partners in U.S. partnerships that invest in PFICs may soon be responsible for filing elections previously filed by the partnership. Under current regulations, U.S. partners may rely on entity-level mark-to-market...more

Proskauer - Tax Talks

The Biden Administration Proposes Changes to the Taxation of Partnerships

Proskauer - Tax Talks on

On March 28, 2022, the Biden Administration proposed certain limited changes to the taxation of partnerships. In short, the Administration’s proposals would (i) prevent related partners in a partnership that has made a...more

Proskauer - Tax Talks

The Biden Administration Re-Proposes to Tax Carried Interests as Ordinary Income

Proskauer - Tax Talks on

On March 28, 2022, the Biden Administration proposed to tax “profits” or “carried” interests as ordinary income and impose self-employment tax on income and gains from these interests for certain partners in investment...more

Stinson LLP

NIIT Expansion Under Proposed Build Back Better Act Includes Subtle Tax Increase on Sales of Private Businesses

Stinson LLP on

In general, tax experts were pleased that the Build Back Better Act, passed recently by the U.S. House of Representatives, did not include many of the tax increases previously proposed by the Biden Administration. ...more

Jones Day

Tightening of German Real Estate Transfer Tax Rules for Share Deals

Jones Day on

The Situation: Under the German real estate transfer tax ("RETT") law, RETT is not only triggered on the direct acquisition of German properties, but also in case of share deals involving companies with German properties, if...more

Foster Garvey PC

Short-Term Rental Update: Airbnb poised for a reprieve in the EU; Guesty offers innovative and more streamlined tools for property...

Foster Garvey PC on

Airbnb poised for a reprieve in the EU - ("Why Airbnb Could Escape the Uber Trap in Europe," Fortune Magazine on Apr 30, 2019) The Court of Justice of the European Union is considering whether Airbnb was breaking the...more

Best Best & Krieger LLP

[WEBINAR] Laying the Foundation for Maximizing Benefits Around Emerging Technologies

This webinar focuses on the important legal and policy foundations that should be considered when integrating emerging technologies into cities and counties. From smart traffic signals and street lights to automated vehicles...more

BCLP

2017 Annual Update – Bryan Cave Private Funds Practice

BCLP on

As we move into a new year, we have taken the opportunity to prepare an Annual Update for our investment adviser and private fund clients. This Annual Update reflects on major statutory and regulatory changes from 2016,...more

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