News & Analysis as of

Partnerships › Capital Losses

Holland & Knight LLP

Proposed Rule Modifies Timing of "Hot Asset" Reporting

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Generally, gain or loss on the sale or exchange of a partnership interest is treated as capital gain or loss except to the extent of so-called "hot assets." Gain attributable to hot assets – generally unrealized receivables...more

Troutman Pepper Locke

Rolling Over and Section 704(c); What's the Big Deal? — Part 2: The Traditional Method

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In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner. As...more

Rivkin Radler LLP

An S Corporation’s Sale of Real Property Following the Death of Its Shareholder

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Don’t Do It- There are certain generally accepted “dos and don’ts” of which almost every investor is certainly aware. For example, do not put all your eggs in one basket; if an investment seems too good to be true, stay...more

Rivkin Radler LLP

Capital vs Ordinary Loss When An Investment Goes South

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Capital Loss- If the amount realized by a taxpayer upon the sale of a partnership interest to a third party is insufficient to restore to the taxpayer their adjusted basis for the interest – i.e., their unrecovered...more

Latham & Watkins LLP

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

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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 business. ...more

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 2 - An Overview of the Tax Act's Effects on Various...

Holland & Knight LLP on

• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Transportation, Ports and Maritime Industry?

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The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Farrell Fritz, P.C.

“Abandonment Of A Partnership Interest,” Or “When A Taxpayer Rejects Its Tax Return Position”

Farrell Fritz, P.C. on

“Disposing” of a Partnership Interest- If the amount realized by a taxpayer upon the sale of a partnership interest to a third party is insufficient to restore to the taxpayer his adjusted basis for the interest – i.e.,...more

McDermott Will & Emery

Inside the New York Budget Bill: Department Issues Guidance Regarding Investment Capital Identification Procedures

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On July 7, 2015, the New York Department of Taxation and Finance issued guidance (TSB-M-15(4)C, (5)I, Investment Capital Identification Requirements for Article 9-A Taxpayers) on the identification procedures for investment...more

Lowndes

Should You Abandon An Underperforming Partnership?

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Good news for taxpayers who have, or who are considering, abandoning an interest in an underperforming partnership. Earlier this week the Fifth Circuit overturned the Tax Court’s 2013 decision in Pilgrim’s Pride, clearing...more

Lowndes

Abandonment Losses Back on the Table!

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Several years ago, many taxpayers faced with underwater partnerships would abandon their partnership interests, thereby triggering an ordinary loss. This ordinary loss was often preferred over the capital loss that would be...more

McDermott Will & Emery

Treasury Finalizes Regulations on Noncompensatory Partnership Options

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The U.S. Treasury Department recently released regulations on the tax treatment of noncompensatory options issued by a partnership, as well as proposed regulations addressing the threshold question of when a partnership...more

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