News & Analysis as of

Tax Liability Tax Cuts and Jobs Act Partnerships

Rivkin Radler LLP

The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?

Rivkin Radler LLP on

In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more

DarrowEverett LLP

How Bonus Depreciation Can Be A Timely Tool in Real Estate Deals

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So, you’re a real estate investor accustomed to tax mitigation strategies and you are starting to think about your next big project. With that comes so many streams of thought — location, timing, interest rates, partnerships,...more

ArentFox Schiff

One, Two, Three, Four . . . Can I Have a Little More? Another State Enacts SALT Cap Workaround

ArentFox Schiff on

While business owners wait to see whether Congress raises the U.S. long-term capital gains rate from 20 percent to 25 percent and enacts relief from the limitations on the deductibility of state and local taxes (SALT),...more

Akin Gump Strauss Hauer & Feld LLP

Secondary U.S. Withholding for Transfers in Private Investment Funds Delayed Until January 1, 2023

Key Points - Fund-level liability for a buyer’s failure to withhold upon secondary market transfer of an LP interest in a fund with ECI assets will apply only for transfers on or after January 1, 2023. Certain...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

Troutman Pepper

Transferring Partnership Interests: Buyer Beware of Withholding Obligations, Seller Beware of Tax Liability - Tax Update Volume...

Troutman Pepper on

The U.S. federal taxation of non-U.S. persons who transfer interests in partnerships has a long and storied history. The government staked out its position in 1991, effectively providing that a non-U.S. partner should be...more

Lowndes

Time to Reconsider Your Choice of Entity?

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One of the most publicized changes made by last year’s Tax Cut and Jobs Act was a reduction in income tax rates for corporations and individuals. The maximum corporate tax rate has been permanently reduced from 35% to 21%,...more

Schwabe, Williamson & Wyatt PC

CPA Shoptalk: 8 Takeaways

On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more

Sherman & Howard L.L.C.

Choosing a Business Entity After the New Tax Act and Other Important Business Tax Changes Under the New Law

Part I: General - The Choice of Entity Decision Prior to 2018 - Since the reduction of individual tax rates in the 1980’s, the decision of whether to conduct a business in the form of a C corporation or in the form of a...more

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