On April 17, 2025, the IRS issued Notice 2025-23, which announced its intent to publish a notice of proposed rulemaking to remove Treasury Regulations Section 1.6011-18 that identifies certain partnership basis adjustment...more
5/21/2025
/ Final Rules ,
Internal Revenue Code (IRC) ,
IRS ,
NPRM ,
Partnerships ,
Proposed Rules ,
Regulatory Agenda ,
Reporting Requirements ,
Tax Basis ,
Tax Planning ,
Taxation ,
U.S. Treasury
On January 10, 2025, the United States Internal Revenue Service (the "IRS") released final regulations (the "Final Regulations") under section 6011 of the Internal Revenue Code of 1986, as amended (the "Code"), that identify...more
On November 29, 2024, the United States Internal Revenue Service (the “IRS”) released final regulations (Final Regulations) relating to the allocation of recourse partnership liabilities under section 752 of the Internal...more
Join Williams Mullen for our hybrid 2025 Winter Tax Forum on Thursday, February 6th. Our speakers, Anna Derewenda, Kyle Wingfield, Kevin Bender, and Patrick Carr will provide an update on the following:
- New Basis...more
1/23/2025
/ Audits ,
Business Taxes ,
Continuing Legal Education ,
Debt Collection ,
Events ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
New Rules ,
Partnerships ,
Rollover Equity ,
S-Corporation ,
Tax Basis ,
Tax Liability ,
Tax Planning
Join Williams Mullen attorneys for our Fall Tax Forum on Wednesday, November 20th, where our speakers will present on certain federal income tax issues with respect to real property transactions including 1031 exchanges, drop...more
10/31/2024
/ Continuing Legal Education ,
Events ,
Federal Taxes ,
Income Taxes ,
IRS ,
Real Estate Investments ,
Real Estate Transactions ,
Related Parties ,
Section 1031 Exchange ,
Tax Deferral ,
Tax Planning ,
Transfer Taxes ,
Wealth Tax
The IRS recently issued Revenue Procedure 2022-19 (“Rev. Proc. 2022-19” or “the Revenue Procedure”), offering taxpayers clarification and new simplified procedures for resolving certain issues related to S corporation...more
Virginia recently enacted legislation that provides an opportunity for the owners of a qualified pass-through entity (PTE) to reduce their federal income tax liability if the PTE makes an election to pay Virginia taxes at the...more
The U.S. Department of Treasury and the Internal Revenue Service recently issued final regulations (“the Final Regulations”) regarding certain aspects of so-called carried interest under Section 1061 of the Internal Revenue...more
2/9/2021
/ Bona Fide Purchaser ,
Capital Gains ,
Carried Interest ,
Final Rules ,
Holding Periods ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
REIT ,
Related Parties ,
Tax Cuts and Jobs Act ,
U.S. Treasury
Earlier this year, the IRS revised Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, and its instructions, to help charities apply for 501(c)(3) tax-exempt status.
In...more
The IRS has released 26 CFR Part 1, resolving questions regarding the five-year period to claim rehabilitation credits for qualified rehabilitation buildings (QRBs). Prior to the proposed regulation, practitioners were...more
In Notice 2020-32, released April 30, the IRS determined that expenses paid using the proceeds of Paycheck Protection Program (PPP) loans (Covered Loans) are not deductible expenses for income tax purposes if those loans...more
On April 9, 2020, the Department of the Treasury (Treasury Department) and the Internal Revenue Services (IRS) issued Notice 2020-23, announcing that certain additional tax return filing and payment deadlines have been pushed...more
4/15/2020
/ Coronavirus/COVID-19 ,
Corporate Taxes ,
Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Popular ,
Relief Measures ,
Tax Extensions ,
Tax Returns ,
Time Extensions ,
U.S. Treasury
On April 8, 2020, the Internal Revenue Service (IRS) released Revenue Procedure 2020-23 (the Revenue Procedure) allowing eligible partnerships subject to the centralized partnership audit regime (CPAR) to amend 2018 and 2019...more
The April 15 deadline for filing tax returns will be postponed until July 15, after comments from Treasury Secretary Steven Mnuchin and Notice 2020-18 posted March 20 by the IRS. This news follows Secretary Mnuchin’s...more
Individuals can delay payments of up to $1 million in taxes and corporations can get payments of up to $10 million deferred until July 15 without interest and penalties, according to a notice published Wednesday. “Americans...more
Treasury Secretary Mnuchin has announced that his department is pushing back the April 15 tax deadline. Individuals and businesses will be granted a 90 day extension to pay taxes they owe....more
In its recently issued opinion in the case of Route 231, LLC v. Commissioner, T.C. Memo 2014-30 (2/24/14), the United States Tax Court (the “Court”) held that a transfer of state tax credits to a 1% member who had contributed...more
4/22/2014
/ Conservation Tax Credit ,
Corporate Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Operating Agreements ,
Partnerships ,
Sale of Assets ,
State Taxes ,
Tax Credits ,
Transfer Taxes ,
Transfers
The Internal Revenue Service (“IRS”) released proposed regulations changing the analysis of whether a partner bears the economic risk of loss for a partnership liability under IRC Section 752. Also, the proposed regulations...more
On January 9, 2014, the Internal Revenue Service (“IRS”) issued a revised version of previously released Rev. Proc. 2014-12, providing a safe harbor for the allocation of IRC Sec. 47 rehabilitation tax credits in tax credit...more
The Internal Revenue Service (“IRS”) recently issued guidance in Rev. Proc. 2014-12, providing a safe harbor for the allocation of IRC Sec. 47 rehabilitation tax credits in tax credit partnerships under IRC Sec. 704(b). The...more