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Tax Reform: Final Regulations Clarify Framework for Determining Pass-Through Income Deduction

Treasury finalizes rules for key component of tax reform for pass-through trades and businesses. Key Points: ..The deduction of up to 20% of pass-through trade or business income effectively may reduce the top marginal...more

IRS Issues Guidance on Transfers by Non-US Partners of Interests in Partnerships With US Assets

Proposed regulations under Section 864(c)(8) provide guidance for determining a foreign partner’s effectively connected gains or losses from a transfer of its interest in a partnership engaged in a US trade or...more

Qualified Opportunity Funds: Investment and Structuring Considerations

Recent guidance from Treasury clarifies fundamental aspects regarding the investment of deferred capital gains in QOFs. Key Points: ..Investors in qualified opportunity funds may derive significant tax benefits in the...more

Impact of the House Tax Reform Bill on the Renewable Energy Sector

Bold proposal seeks changes to tax credits, depreciation, and corporate tax rates. Key Points: - Production Tax Credits are cut by more than one-third. - Bill may impact existing and future tax equity...more

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