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New Proposed Regulations Increase Scrutiny on Related-Party Debt

USA - June 30 2016 New rules recently proposed by the U.S. Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") would re-characterize purported...

Steven E. Clemens, Edward P. Lemanowicz, Joshua Milgrim.


Recent Changes to Rules Governing Tax Audits of Partnerships

USA - March 29 2016 Congress recently amended the rules governing tax audits of partnerships that file U.S. partnership returns, including U.S. partnerships (and limited...

Adrienne M. Baker, Joshua Milgrim.


Navigating the New Partnership Audit Rules: Sea Change or Same Course?

USA - February 1 2016 The recently enacted Bipartisan Budget Act of 2015 amended existing Internal Revenue Code of 1986, as amended (the “Code”) rules governing tax audits...

Jay Zagoren, Adrienne M. Baker, Daniel M. Dunn.


Publicly traded partnership proposed regulations

USA - June 23 2015 Widely held partnerships are a significant source of funding for oil, gas and certain natural resources projects, but the publicly traded partnership...

Jay Buchman, Michael A. Lehmann, Michael Hirschfeld, Daniel M. Dunn.


US energy excise tax proposed legislative changes

USA - April 14 2015 Federal excise taxes imposed on natural gas, propane and other alternative fuels can significantly add to their cost and can create a disincentive to...

Jay Buchman, Michael A. Lehmann, Michael Hirschfeld.