Patrick J. McCurry
McDermott Will & Emery
Articles
IRS Issues Proposed Regulations Intended to Clarify Carried Interest Rules
USA - August 24 2020 The Internal Revenue Service (IRS) recently issued proposed regulations under section 1061, a provision enacted as part of the Tax Cuts and JOBS Act…
Kevin Hall, Alejandro Ruiz, Thomas P. Ward, Gregory M. Weigand
IRS Publishes Proposed Section 199A Regulations
USA - August 24 2018 The IRS recently issued proposed regulations under Section 199A, a provision enacted as part of tax reform to allow individuals and certain other…
The IRS Releases CCA 201606027
USA - March 23 2016 On February 5, 2016, the Internal Revenue Service (IRS) released Chief Counsel Advice 201606027 (the 2016 CCA) in which the IRS concluded, among…
Proposed regulations require significant entrepreneurial risk for a service partner's income to be a distributive share
USA - August 18 2015 On July 22, 2015, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released proposed regulations under Section 707(a)(2)(A)…
Treasury finalizes regulations on noncompensatory partnership options
USA - February 27 2013 The U.S. Treasury Department recently released regulations on the tax treatment of noncompensatory options issued by a partnership, as well as…
