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 our seasoned tax and estate planning attorneys on Wednesday, May 17th in Norfolk for the Williams Mullen Spring Tax Forum. Breakfast will be provided.
This program will dig into complex private equity structures, how...more
4/21/2023
/ Business Entities ,
Business Losses ,
Business Taxes ,
Continuing Legal Education ,
Convertible Debt ,
Estate Planning ,
Events ,
Partnerships ,
Private Equity ,
Safe Harbors ,
Tax Planning ,
Wealth Management
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
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
As part of the 2017 tax overhaul, provisions were put in place that allowed those holding property for rental purposes to write off up to a fifth of their rental income for tax purposes. The deduction was included in Code...more
10/18/2019
/ Business Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Partnerships ,
Pass-Through Entities ,
Property Owners ,
Real Estate Brokers ,
Real Estate Investments ,
Rental Income ,
Revenue Procedures ,
S-Corporation ,
Safe Harbors ,
Sole Proprietorship ,
Tax Deductions ,
Tax Reform
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
The United States Tax Court recently issued its opinion in Crescent Holdings, LLC v. Commissioner, 141 T.C. No. 15 (12/2/13), a ruling regarding allocations of income attributable to an unvested partnership interest. The...more