News & Analysis as of

Partnerships Wealth Tax

Allen Barron, Inc.

How Did Moore v. United States Change U.S. Tax Law?

Allen Barron, Inc. on

We have been waiting several months for the Supreme Court of the United States (SCOTUS) to render a decision in Moore v. United States. Initially, our questions focused on the issue of “realized or unrealized income” and...more

Williams Mullen

No Moore Waiting - Supreme Court Upholds Mandatory Repatriation Tax

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On June 20, the U.S. Supreme Court released its opinion in the closely watched case of Moore v. United States. In a 7-2 decision, the court upheld the constitutionality of the mandatory repatriation tax (MRT), also referred...more

Farella Braun + Martel LLP

The IRS Is Targeting Partnership Transactions: Is Your Representative Ready?

Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more

Rivkin Radler LLP

“C’mon Man! Tax the Rich!” Business Owners Face Tax Increases*

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Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate. Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.Perhaps the Senator...more

Kohrman Jackson & Krantz LLP

IRS Cracks Down on High-Income Earners

Since the Internal Revenue Service (IRS) has received its supplemental funding under the Inflation Reduction Act, the IRS has continuously focused on high-income earners, partnerships, and large corporations. Under its most...more

Warner Norcross + Judd

The IRS is Shifting Audit Attention to Large Partnerships and Wealthy Individuals

Warner Norcross + Judd on

In 2009, the IRS created its Global High Wealth Industry Group, known more familiarly as the “Wealth Squad.” This group starts with an examination of a “key case,” which is typically a wealthy person’s individual tax return,...more

Skadden, Arps, Slate, Meagher & Flom LLP

The IRS Is Coming for Partnerships and High Net Wealth Individuals

The Internal Revenue Service plans to deploy thousands of new hires to expand audits of partnerships and high net wealth individuals. As part of a larger transformation at the agency, it is using some of the $60 billion in...more

Skadden, Arps, Slate, Meagher & Flom LLP

Real World Examples Where Conflicts Tainted a Deal Process, and Other Deals That Were Insulated From Conflicts

Sometimes when a board is considering a strategic transaction, it may find that a key figure who can influence the deal process — for example, a founder, controller or CEO-negotiator — has a potential conflict of interest....more

Skadden, Arps, Slate, Meagher & Flom LLP

The Informed Board - Fall 2023

Boards routinely confront an array of difficult issues. In this issue of The Informed Board, we tackle four of the thorniest and most topical: - How to preserve the integrity of a deal process where a key fiduciary (say,...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Rolls Out Long-Planned Strategy Targeting Large Partnerships and High-Wealth Individual Taxpayers

On September 8, 2023, Internal Revenue Service (IRS) Commissioner Danny Werfel announced the rollout of a coordinated enforcement strategy that will involve audits of returns filed by 75 of the largest partnerships operating...more

Rivkin Radler LLP

The Closely Held Business and The Tax Gap

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Have you ever wondered whether you were barking up the wrong tree? That the solution to a problem may be found, not in the approach to which you were already committed and invested, but in an altogether different direction?...more

Rivkin Radler LLP

S Corps with Real Property: Separating Shareholders & Partnership Envy

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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

Rivkin Radler LLP

Tax Hikes, Effective Dates, And Selling a Business

Rivkin Radler LLP on

Living the Dream- “How was your weekend?” Thank you for asking. Awful. “Why?” you ask. (Humor me. Pretend you’re interested.) I’ll tell you. One word, with 535 syllables: Congress. When the reconciliation budget...more

Rivkin Radler LLP

Partners, S Corp. Shareholders And Biden’s 2022 Revenue Proposal: No More Business As Usual

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What A Ride- No one anticipated that the Administration’s proposed tax increases would fly through Congress easily – at least no one residing in a state in which the recreational use of marijuana has not been legalized....more

Skadden, Arps, Slate, Meagher & Flom LLP

Increased Funding Would Support IRS Drive To Audit More Partnerships and Wealthy Individuals

More — and more rigorous — IRS examinations are coming. The Biden administration is committed to closing the “tax gap” (the difference between taxes owed and taxes actually paid on time). Increased enforcement efforts are...more

Perkins Coie

IRS to Target High Net Worth Individuals, Private Foundations, and Associated Entities Beginning in July 2020

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The Internal Revenue Service (IRS) intends to audit hundreds of high net worth individuals and their related entities starting this month. The campaign, announced at a conference by a top IRS division commissioner, will...more

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