Temporary regulations issued by the IRS amend an existing safe harbor that is used for determining whether allocations of CFTEs are deemed to be in accordance with the partners’ interests in the partnership.
There are risks are associated with valuing carried interest transfers.
If the general partner has unfettered discretion to make or withhold distributions, any gift of an interest in the partnership may be treated as a gift of a future interest not qualifying for the annual gift tax exclusion.
The IRS requested comments on several issues to assist it in issuing regulations to implement the new rules for partnership audits that were passed by Congress last year to replace the long-standing TEFRA audit regime.
New rules released by the IRS are intended to improve an existing safe harbor for allocating creditable foreign taxes so that they are deemed to be in accordance with the partners’ interests in the partnership.
This article discusses developments in income allocations, disguised sales, partnership distributions, terminations, and basis adjustments.
The Bipartisan Budget Act of 2015 greatly strengthened the IRS’s ability to examine certain partnerships.
This article discusses the tax treatment of worthless or abandoned stock and partnership interests.
Practitioners should be familiar with the cancellation-of-debt rules to ensure that modifications of an LLC's debts are not significant enough to cause the members to recognize income.
The act replaces the current TEFRA partnership audit rules and repeals the current special rules for electing large partnerships.
The regulations would create an exception to the general nonrecognition rule for property contributions to a partnership in exchange for a partnership interest.
This second article in a two-part series explores common tax considerations preceding and following an IPO employing an Up-C structure.
IRS Chief Counsel Advice interpreted whether Sec. 752 should be used to determine whether a partnership’s debt is recourse or nonrecourse for purposes of COD income rules.
This first article in a two-part series covers the Up-C’s basic structure and how it is implemented.
The new rules would apply to partnership returns filed for tax years beginning after Dec. 31, 2017.
A partnership distribution may consist of cash, property, or both. In addition, any reduction of a partner’s share of partnership liabilities is treated as an actual distribution of cash.
This item explores some common issues encountered by foreign taxpayers adopting transparent U.S. LLCs to invest or operate in the United States.
A consent to extend the limitation period for the assessment for partnership items signed by the tax matters partner of a partnership in his capacity as the tax matters partner of another partnership was valid because the individual had the apparent authority to sign the consent.
The IRS issued proposed regulations that require a nonexclusive six-factor test to determine whether payments from a partnership to a partner are disguised payments.
The IRS intends to issue regulations under Sec. 721(c) to ensure that a U.S. person recognizes gain either immediately or periodically when it transfers certain property to a partnership that has foreign partners related to the transferor.