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The IRS has issued new guidance to prevent related parties from using partnerships to achieve tax benefits through basis-shifting among assets. The IRS recently released a guidance package aimed at preventing...more
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
Limited liability companies (LLCs) offer significant tax flexibility – for one thing they can elect to be treated as disregarded entities, partnerships, C corporations, or S corporations, and can even shift between those tax...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 14 – October 18, 2019. October 15, 2019: The IRS published a news release that...more
On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more
• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more
Good news for taxpayers who have, or who are considering, abandoning an interest in an underperforming partnership. Earlier this week the Fifth Circuit overturned the Tax Court’s 2013 decision in Pilgrim’s Pride, clearing...more