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House Rules Committee’s revisions to One Big Beautiful Bill include amendment to partnership disguised sale rules

On May 22, 2025, the House of Representatives passed the highly anticipated budget reconciliation bill, referred to as the “One Big Beautiful Bill,” with revisions from the House Rules Committee. On May 21, 2025, the House...more

Surviving the fallout: Special issues facing syndicated conservation easement investors

In recent months, the IRS has continued its attack on syndicated conservation easement transactions. Many syndicated partnerships are now under IRS audit or have cases pending before the US Tax Court. Moreover, the IRS has...more

A new life for leveraged partnership structures; Treasury and the IRS issue proposed regulations under the disguised sale rules

On June 19, 2018, Treasury and the Internal Revenue Service (IRS) published proposed regulations (REG-131186-17) (2018 Proposed Regulations) concerning the manner in which partnership liabilities are allocated among the...more

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