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Proposed Regulation › 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...

Pillsbury Winthrop Shaw Pittman LLP on

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

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...

Cadwalader, Wickersham & Taft LLP on

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

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