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Internal Revenue Service Related Parties Income Taxes

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Rivkin Radler LLP

Writing Off A Loan – Simultaneous COD Income and Bad Debt Deduction? Not Necessarily

Rivkin Radler LLP on

If you’ve been around closely held businesses long enough, you know that a transfer of money between a business and its owner, or between two related businesses, is sometimes characterized by the parties as a loan (“related...more

Williams Mullen

[Event] 2024 Fall Tax Forum - November 20th, Richmond, VA

Williams Mullen on

Join Williams Mullen attorneys for our Fall Tax Forum on Wednesday, November 20th, where our speakers will present on certain federal income tax issues with respect to real property transactions including 1031 exchanges, drop...more

Eversheds Sutherland (US) LLP

IRS issues final (for now) debt/equity regulations

Final regulations addressing the treatment of certain related-party indebtedness as equity for US federal income tax purposes were released on May 13, 2020. The regulations finalize without material change regulations that...more

Butler Snow LLP

Non-US Persons Holding US Real Estate: Penalties For Failing To File Certain IRS Forms Are Increasing To $25,000

Butler Snow LLP on

Most non-US persons who are properly advised regarding US real estate ownership will structure their holdings to include some combination of US LLCs, non-US companies, non-US partnerships, non-US trusts and/or non-US...more

Troutman Pepper Locke

Related-Party Provisions Prevent Deduction by S Corp Shareholders - Tax Update Volume 2017, Issue 4

Troutman Pepper Locke on

Many routine transactions occur between related parties, including the payment or accrual of interest on indebtedness, license fees, salary or benefits to employees and/or shareholders, and trade invoices. The Tax Court...more

Eversheds Sutherland (US) LLP

State Tax Fallout From Federal Proposed Related-Party Debt Regulations

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more

Latham & Watkins LLP

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Latham & Watkins LLP on

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

Eversheds Sutherland (US) LLP

Taking Stock in Related-Party Debt: Regulations Propose Sweeping Changes

On April 4, the Treasury and the Internal Revenue Service (IRS) released proposed regulations under IRC § 385 (the Proposed Regulations) that are intended to combat perceived concerns associated with indebtedness between...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Treasury Releases Notice Addressing Transactions Involving Related-Party Partnerships"

On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more

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