Joshua M. R. Becker

Joshua M. R. Becker

Herbert Smith Freehills Kramer

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Long-Awaited Treasury Regulations Address the Application of Section 1061 to Carried Interests

On July 31, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REGS-107213-18) (Proposed Regulations) governing the treatment of “carried interests” (also...more

8/20/2020  /  APIs , Carried Interest , Carried Interest Tax Rates , Internal Revenue Code (IRC) , IRS , Partnership Interests , Tax Cuts and Jobs Act , Tax Planning , U.S. Treasury

New Treasury Regulations Address Disallowance of Deductions for Fines, Penalties and Other Amounts

On May 12, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-104591-18) that address the disallowance of deductions for amounts paid or incurred for...more

5/21/2020  /  Fines , Internal Revenue Code (IRC) , IRS , Penalties , Section 162(f) , Settlement , Tax Deductions , U.S. Treasury
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