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IRS Provides Interim Guidance Regarding Withholding Obligations with Respect to Dispositions of Interests in Partnerships

USA - April 3 2018 The recent tax reform legislation, commonly known as the Tax Cuts and Jobs Act, imposed new withholding obligations on the transfer by a non-U.S…

Jon Nelsen, Richard A. Husseini, Michael P. Bresson, Stephen D. Marcus, Don J. Lonczak, Robert W. Phillpott

Winter is Coming: New Partnership Audit Rules Effective January 1, 2018

USA - September 11 2017 Radical changes in the law governing IRS income tax audits of tax partnerships (“New Partnership Audit Rules”) are generally effective for tax years…

Jon Nelsen, Richard A. Husseini, Michael P. Bresson, Stephen D. Marcus, T. Chuck Campbell, Don J. Lonczak, Ryan Phelps, Robert W. Phillpott, Ron J. Scharnberg

IRS Releases Final Regulations on MLP Qualifying Income

USA - January 20 2017 On January 19, 2017, the Department of the Treasury and the Internal Revenue Service (IRS) issued final regulations (available here) on the scope of…

James Chenoweth, Michael P. Bresson, Stephen D. Marcus, T. Chuck Campbell

IRS Issues Final, Temporary and Proposed Regulations Regarding Partnership Disguised Sale and Liability Allocation Rules

USA - October 21 2016 On October 5, 2016, the IRS and the Department of the Treasury published Final Regulations, Temporary Regulations and Proposed Regulations governing…

James Chenoweth, Michael P. Bresson, Stephen D. Marcus, Don J. Lonczak

Targeting Inversions, Treasury Proposes Debt Reclassification Regulations with Potentially Sweeping Impact on Related-Party Financing Arrangements

USA - April 20 2016 On April 4, 2016, the U.S. Department of the Treasury announced the release of new temporary and proposed regulations aimed at curbing the practice…

Richard A. Husseini, Jon Lobb, Derek S. Green, Don J. Lonczak, Christopher Morales