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Williams Mullen

Better Late Than Never - The IRS Issues Final Regulations on the Allocation of Recourse Partnership Liabilities After More Than a...

Williams Mullen on

On November 29, 2024, the United States Internal Revenue Service (the “IRS”) released final regulations (Final Regulations) relating to the allocation of recourse partnership liabilities under section 752 of the Internal...more

Cadwalader, Wickersham & Taft LLP

IRS Issues Final Partnership Basis Shifting Regulations

Cadwalader, Wickersham & Taft LLP on

On January 10, 2025, the Treasury and IRS issued final regulations identifying certain partnership related party “basis shifting” transactions and substantially similar transactions as transactions of interest (TOIs), which...more

Proskauer - Tax Talks

Final Regulations Issued on Allocation of Partnership Liabilities Under Section 752

Proskauer - Tax Talks on

On December 2, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations (the “Final Regulations”) on section 752 regarding the allocation of partnership...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Morrison & Foerster LLP on

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

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