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, Patrick J. McCurry, Alejandro Ruiz, Gregory M. Weigand
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…
Kevin Hall, Patrick J. McCurry, Alejandro Ruiz
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)…
Kevin J. Feeley, Patrick J. McCurry
USA - July 17 2014
It is important for private equity purchasers to mitigate the creation of Subpart F income in structuring the acquisition and holding of the stock of…
Jeffrey C. Wagner, Daniel N. Zucker
USA - April 15 2013
It has long been the case that venture funds (classified as partnerships for tax purposes) have insisted that limited liability companies (LLCs)…