The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more
7/9/2024
/ Asset Management ,
Corporate Taxes ,
IRS ,
New Guidance ,
New Regulations ,
Notice of Proposed Rulemaking (NOPR) ,
NPRM ,
Partnerships ,
Pass-Through Entities ,
Popular ,
Proposed Regulation ,
Revenue Rulings ,
Tax Basis ,
Tax Reform ,
U.S. Treasury
In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more
2/14/2024
/ Appeals ,
Business Entities ,
Commercial Litigation ,
Exclusions ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Limited Partnerships ,
Partnerships ,
Self-Employment Tax ,
Tax Court ,
Tax Exemptions ,
Tax Planning