Corporate Divorce – Preventing and Managing the Break-Up of a Business Partnership
Podcast - Colaborar por contrato... sí funciona
Law School Toolbox Podcast Episode 495: Listen and Learn -- Partnership Liability
The Entrepreneur's Journey with Kass and Mike Lazerow
5 Key Takeaways | Debating Critical Issues Facing the Banking Industry
When a co-shareholder purchases the debt obligations of the company without partners' knowledge
Bar Exam Toolbox Podcast Episode 269: Listen and Learn -- Creation of Partnerships
An Alternative to Consolidations: Key Considerations for Management Services Organizations
Succession Planning to Safeguard Your Law Firm’s Future: On Record PR
Physician Partnership Agreements: Setting Yourself Up for Success
The Current Landscape of Bank-Fintech Partnerships - The Consumer Finance Podcast
Strategic Restructuring for the Future, Putting a Plan Into Action: A Conversation With Gloria Brooks on Building End-of-Life Partnerships
Into the Future: Modern Partnerships in Health Care Construction Delivery
NGE On Demand: Profits Interests: Granting & Receiving with Patty Cain and Josh Klein
PODCAST: Williams Mullen's Trending Now: An IP Podcast - Cause Marketing: Do’s and Don'ts
Navigating the LLC Jungle - I Know a Lawyer Podcast
Sitting with the C-Suite: Managing the Merger and Looking Toward the Future
Sitting with the C-Suite: Finding the Right Fit
Sitting with the C-Suite: AI as the Future of eDiscovery
Sitting with the C-Suite: Reveal's Acquisition of NexLP – Making Bold Moves by Leading with AI
Section 1202 of the Internal Revenue Code provides that noncorporate taxpayers may exclude certain gains on the disposition of Qualified Small Business Stock (QSBS) held longer than the minimum required holding period. One...more
An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more
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
The IRS recently released a trio of Revenue Procedures - 2021-48, 2021-49, and 2021-50 - related to the Paycheck Protection Program (PPP), which has been the subject of a number of our previous legal alerts. Some alerts can...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 20 – 24, 2021. September 22, 2021: The US Department of the Treasury (Treasury) and...more
On September 13, 2021, the Congressional House Ways and Means Committee introduced 880 plus pages of legislative tax proposals to help fund the House’s proposed $3.5 trillion stimulus package. Below are tax proposals relevant...more
On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 24 – 28, 2020. February 24, 2020: The IRS released final instructions to Form 8978,...more
A recent case from the Western District of Wisconsin, In re Schroeder Brothers Farms of Camp Douglas LLP, may raise a new issue for the bankruptcy treatment of tax attributes in flow-through entities. The court in Schroeder...more
Final regulations relating to the determination of the foreign tax credit following the Tax Cuts and Jobs Act were released earlier this month. Though largely similar to the proposed regulations, taxpayers may be interested...more
On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more
On May 23, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (TD 9859) (the Final Regulations) modifying the application of section 956 of the Internal Revenue...more
A limited liability company (an “LLC”) is a business structure created by state statute, but it is not a distinct business entity for tax purposes (like a partnership or a corporation). Instead, businesses structured as LLCs...more
While mid-April is typically associated by most with Tax Day, this year, April 2019, also became the month the highly awaited second round of Qualified Opportunity Zone Proposed Regulations were issued....more
2018 was a very active year for tax developments. The big story was the application of the substantial reforms of the Tax Cuts and Jobs Act of 2017, which took initial effect in 2018. But there were several other developments...more
Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects. On November 26, 2018, the Treasury and...more
On November 26, 2018, the U.S. Treasury released proposed regulations under section 163(j) of the Internal Revenue Code, which, as amended by last year's tax reform, generally limits deductibility of net business interest...more
A recent case, Lender Management LLC v. Commissioner of Internal Revenue, T.C. Memo. 2017-246, has created a window of opportunity for family offices to restructure their affairs and potentially deduct certain family office...more
Public Law 115-97 (the Tax Cuts and Jobs Act (TCJA)) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. On September 13, 2018, the Department of the Treasury...more
President Trump signed into law the Tax Cuts and Jobs Act (the “TCJA”) on December 22, 2017. Included in the TCJA were amendments to IRC §168(k), which permits taxpayers to expense 100% of the costs of certain qualified...more
New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more
On April 11, 2018, the General Assembly’s Revenue Laws Study Committee released a draft tax bill for possible introduction in the legislative session that convenes May 16. This Alert provides a summary of the more important...more
On March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The announcement of these new campaigns reiterates LB&I’s efforts to focus...more
On March 13, 2018, the Internal Revenue Service’s Large Business and International Division announced that it was adding five more compliance campaigns to its previously-announced list of 24 such campaigns. The compliance...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more