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
Legislation impacts tiered partnerships and M&A transactions. Existing partnerships should review operating agreements before new rules take effect.
The Bipartisan Budget Act of 2015 (the Act), which President Obama...more
Proposed Regulations seek to curtail perceived abuses, including the use of “bottom-dollar” guarantees and some indemnity arrangements.
On January 29, 2014, the Internal Revenue Service (IRS) proposed regulations that...more