As part of the US federal tax reform in 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended (the "Code"), to provide incentives economic growth and investment in designated...more
4/24/2019
/ Anti-Abuse Rule ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Opportunity Zones ,
Partnerships ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Transactions ,
S-Corporation ,
Safe Harbors ,
Tangible Property ,
U.S. Treasury
Beginning in 2018, partnerships (meaning an entity treated as a partnership for tax purposes) generally are subject to the new partnership audit rules. Partnerships may elect out of the new partnership audit rules if they (1)...more
Katten previously alerted our readers to the changes in partnership audit rules [See Katten Advisory, "New Partnership Audit Regime Set to Take Effect in 2018, Proactive Planning Recommended," August 7, 2017]. The Internal...more
The Tax Cuts and Jobs Act proposed by the US House of Representatives on November 2 (House Bill) proposes major modifications to employee and partner compensation and benefits-related provisions of the Internal Revenue Code,...more
11/10/2017
/ Carried Interest ,
Corporate Taxes ,
Deferred Compensation ,
Excise Tax ,
Executive Compensation ,
Income Taxes ,
Individual Retirement Account (IRA) ,
Internal Revenue Code (IRC) ,
Partnerships ,
Pending Legislation ,
Recharacterization ,
Section 409A ,
Tax Exempt Entities ,
Tax Reform ,
Vesting
On November 2, 2015, Congress passed the new centralized partnership audit regime as part of the Bipartisan Budget Act of 2015 (BBA) which is set to take effect for the tax years beginning on or after January 1, 2018. The...more