On May 28, 2025, in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) (“Soroban II”), the Tax Court held the active role of limited partners in a fund manager caused them to fail to qualify as “limited partners”...more
On May 12, 2025, House Republicans unveiled a comprehensive 389-page package of tax provisions, setting the stage for a significant tax bill to be debated in the coming weeks. Dubbed the “One Big Beautiful Bill,” this...more
On July 31, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) providing guidance on Section 1061 of the Code, as...more
8/10/2020
/ APIs ,
Capital Gains ,
Capital Gains Tax ,
Carried Interest ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnership Interests ,
Partnerships ,
Pass-Through Entities ,
Private Equity ,
Proposed Regulation ,
Recharacterization
On May 13, 2019, the U.S. Internal Revenue Service (“IRS”) and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions...more
5/23/2019
/ FIRPTA ,
Foreign Persons ,
Income Taxes ,
International Tax Issues ,
IRS ,
K-1 ,
Partnerships ,
Proposed Regulation ,
Reporting Requirements ,
Shareholders ,
Withholding Requirements
Introduction -
On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section...more
4/30/2019
/ Anti-Abuse Rule ,
Capital Gains ,
Carried Interest ,
Holding Periods ,
Opportunity Zones ,
Original Use ,
Partnerships ,
Preamble ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments ,
REIT ,
Reporting Requirements ,
S-Corporation ,
Safe Harbors ,
Tax Cuts and Jobs Act
The Bipartisan Budget Act of 2015, signed into law on November 2, 2015, has significantly changed the partnership tax audit rules, effective for tax years beginning after December 31, 2017.
Under the current partnership...more
11/6/2015
/ Audits ,
Bipartisan Budget ,
Burden-Shifting ,
Federal Budget ,
IRS ,
Joint and Several Liability ,
New Legislation ,
New Regulations ,
Partnership Agreements ,
Partnerships ,
Registered Representatives ,
Tax Liability