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Private Equity Partnerships Proposed Regulation

Skadden, Arps, Slate, Meagher & Flom LLP

The IRS Takes Aim at Basis Adjustments in Partnership Transactions

On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships: In new proposed regulations, the IRS identified several...more

Vinson & Elkins LLP

IRS, Treasury Look to Challenge So-Called Basis-Shifting Transactions, But It Won’t Be Easy

Vinson & Elkins LLP on

The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) announced the latest chapter in the long-trumpeted enforcement initiative aimed at large partnerships. The guidance, summarized below,...more

Ballard Spahr LLP

Carried Interest – Proposed Regulations and the Impact on Private Equity

Ballard Spahr LLP on

Treasury and the IRS released proposed regulations under Section 1061 of the Internal Revenue Code (the Code) on July 31, 2020, that require certain taxpayers to satisfy a three-year holding period, rather than a one-year...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

Jackson Walker

Proposed Treasury Regulations Address Private Equity Management Fee Waivers and Profits Interests

Jackson Walker on

The Internal Revenue Service ("IRS") and Treasury Department recently released proposed regulations under section 707(a)(2)(A) of the Internal Revenue Code of 1986 (the "Code) addressing the issuance of certain interests in...more

Dechert LLP

Global Private Equity Newsletter - Fall 2015 Edition: Proposed Partnership Treasury Regulations – Consider the Guaranteed Payment

Dechert LLP on

Proposed regulations were issued under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the “Code”), that address circumstances when certain arrangements between partnerships and their partners will be...more

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