On December 2, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations (the “Final Regulations”) on section 752 regarding the allocation of partnership...more
Section 1402(a)(13) of the Internal Revenue Code provides that the distributive share of “limited partners, as such” from a partnership is not subject to self-employment tax.[1] Managers of private equity and hedge funds are...more
On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more
11/2/2016
/ Acquisitions ,
Bifurcation ,
Corporate Taxes ,
De Minimus Quantity Exemption ,
Debt Instruments ,
Debt-Equity ,
Disregarded Entities ,
Distribution Rules ,
Expanded Group Instruments (EGIs) ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
S-Corporation ,
Section 385 ,
Securities ,
Stocks