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Newly Proposed Partnership Audit Rules Allow for Multiple-Tier “Push-Out” Election

USA - December 19 2017 The U.S. Department of the Treasury (the "Treasury") and the U.S. Internal Revenue Service (the "IRS") have issued a new installment of proposed...


The Impact of New U.S. Partnership Audit Rules on Investment Partnerships in the U.S. and Abroad: Hidden Mines in the Road to Increased Tax Revenue

USA - December 19 2016 The U.S. Bipartisan Budget Act of 2015 amended the provisions of the U.S. Internal Revenue Code of 1986, as amended (Code), governing partnership...


Much-Anticipated Section 871(m) Dividend Equivalent Guidance Provides Promised Transition Relief

USA - December 7 2016 The U.S. Internal Revenue Service (the "IRS") has released Notice 2016-76, providing anticipated guidance and transition relief for certain dividend...


Section 871(m) Dividend Equivalent Guidance Including New Transition Relief Expected After Mid-November

USA - October 25 2016 The U.S. Internal Revenue Service (the “IRS”) plans to release a guidance package including final rules and transition relief for dividend equivalent...


Partnership Audits of Private Equity Firms on the Rise

USA - March 31 2016 There has been buzz in the tax and private equity communities about the rise in audits of private equity firms by the Internal Revenue Service...

Michael A. Lehmann, Daniel M. Dunn, Joshua Milgrim.