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Partnerships › Tax Planning › Investment Funds

Cadwalader, Wickersham & Taft LLP

Congress Targets Partnership Disguised Sales and Services

Cadwalader, Wickersham & Taft LLP on

Both the House’s and Senate’s budget bills would clarify that certain rules applicable to disguised payments for services and disguised sales of property between a partner and a partnership under Section 707(a)(2) are...more

McDermott Will & Schulte

Receiving Debt-Financed Distributions From a QOF: IRS Allows Significant Flexibility (And Some Traps)

McDermott Will & Schulte on

Qualified Opportunity Funds (QOFs) offer generous tax incentives but are bound by a complicated set of rules, not to mention the complexity of Subchapter K of the Internal Revenue Code (IRC), as QOFs are typically organized...more

Gray Reed

The Basis Matrix: Navigating the Interplay of Sections 743(b) and 734(b)

Gray Reed on

Real estate funds and family offices are two types of investors that often (i) purchase equity interests in partnerships and (ii) make in-kind asset distributions for tax planning purposes. Well advised real estate and family...more

Morgan Lewis

Taxpayer Victory in US Tax Court Highlights Need for Properly Structuring Partnership Profits Interests

Morgan Lewis on

A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a...more

McDermott Will & Schulte

Highlights from the Final Opportunity Zone Regulations

McDermott Will & Schulte on

The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more

Miles & Stockbridge P.C.

2nd Tranche of OZ Regulations

Miles & Stockbridge P.C. on

On April 16, 2019, Treasury issued its second set of proposed regulations (“OZ Regs 2”) regarding Section 14002 of the Internal Revenue Code of 1986, as amended (the “Code”). The OZ Regs 2 are very helpful and answer a...more

Flaster Greenberg PC

Guide to the Surprises Lurking in the QOZ Proposed Regulations

Flaster Greenberg PC on

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

Bowditch & Dewey

Op Funds Expand Deferral Paths for CRE Investors

Bowditch & Dewey on

BOSTON — The Tax Cuts and Jobs Act of 2017 created the Opportunity Zone program which provides real estate investors a new tool to defer gains from sales or exchanges of capital assets by investing those gains in a “Qualified...more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update

Sheppard Mullin Richter & Hampton LLP on

Background – In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income communities designated by the IRS as qualified...more

Jackson Walker

Treasury Releases Qualified Opportunity Fund (QOF) Guidance

Jackson Walker on

On October 19, the Treasury Department released a first round of guidance bringing much needed clarity to certain aspects of the Qualified Opportunity Fund regime enacted by the Tax Cuts and Jobs Act. While important...more

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