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IRS Proposes Regulations for Withholding on Transfers of Partnership Interests

The US Internal Revenue Service (IRS) issued proposed regulations on May 7 that would expand tax withholding and reporting requirements in certain sales or exchanges of interests in partnerships engaged in one or more US...more

IRS Makes Changes to EIN Application Process

The Internal Revenue Service issued new instructions for the Employer Identification Number application process in December 2017. Unless an applicant is a government entity, the applicant’s “responsible party” must now be an...more

M&A and Tax Reform—New Tax Considerations with Wide-Ranging Implications

New tax provisions have significant impact on structuring mergers and acquisitions. In light of the recent passage of HR 1 (the Act) and ensuing sweeping changes to tax law in the United States, certain tax-related aspects...more

Tax Reform Legislation Reverses Grecian Magnesite Mining, Adds New Withholding Tax

New provisions will have a significant impact on secondary sales of fund interests and partnership M&A transactions. On December 22, 2017, US President Donald Trump signed into law the sweeping tax reform bill H.R. 1 (the...more

Tax Reform Legislation Addresses UBIT and Segregation of UBTI Investments

Adopting the Senate’s approach, tax reform legislation will not require governmental pension plans to be subject to unrelated business income tax, and tax-exempt entities subject to tax on unrelated business taxable income...more

Tax Reform Bill Proposes to Eliminate UBTI Exemption for Government Plans

House bill, if enacted, will alter tax analysis with respect to fund investments. On November 2, House Republicans released their draft tax reform bill. Of particular interest to government pension plans is a provision...more

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