Jeff Romero

Skadden, Arps, Slate, Meagher & Flom LLP

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The IRS Takes Aim at Basis Adjustments in Partnership Transactions

On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships: In new proposed regulations, the IRS identified several...more

6/25/2024 / Federal Taxes , Income Taxes , Internal Revenue Code (IRC) , Investment Management , IRS , Partnerships , Private Equity , Proposed Regulation , Revenue Rulings , Taxation

Observations on Notice 2023-80: The Treasury Department and IRS’ Preliminary Guidance on the Interaction of Foreign Tax Credit and...

On December 11, 2023, the Department of the Treasury (the Treasury Department) and the Internal Revenue Service (IRS) released much-anticipated guidance in Notice 2023-80 (Notice) announcing their intention to issue proposed...more

12/20/2023 / Foreign Tax Credits , Internal Revenue Code (IRC) , IRS , Partnerships , Pillar 2 , Relief Measures , Tax Credits , Taxation , U.S. Treasury

IRS Issues Notice on Payments Made in Exchange for State and Local Tax Credits

On May 23, 2018, the Department of the Treasury and the Internal Revenue Service (IRS) issued Notice 2018-54, stating that proposed regulations will be issued addressing the deductibility of certain payments made by taxpayers...more

5/29/2018 / IRS , Local Taxes , Qualified Charitable Distributions , State and Local Government , State Taxes , Tax Credits , Tax Cuts and Jobs Act , Tax Deductions , U.S. Treasury

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