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Tax Credits › Taxation › Partnerships

Miller Canfield

Are Wages for Research Credit Purposes Limited to “Reasonableness?”

Miller Canfield on

Smith v. Commissioner, a pending research credit case in the United States Tax Court, presents an issue of first impression: Is a partner’s self-employment income in a partnership allowable as a qualified research expense...more

Cozen O'Connor

Drafting Partnership Agreements: Ensuring You Get the Returns You Bargained For

Cozen O'Connor on

PIP (partners' interests in the partnership) allocations are very commonly used in partnership agreements. For this reason, Investors and managers should understand the basics of PIP allocations and whether and when they...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Pillsbury Winthrop Shaw Pittman LLP on

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

Skadden, Arps, Slate, Meagher & Flom LLP

Observations on Notice 2023-80: The Treasury Department and IRS’ Preliminary Guidance on the Interaction of Foreign Tax Credit and...

Skadden, Arps, Slate, Meagher & Flom LLP on

On December 11, 2023, the Department of the Treasury (the Treasury Department) and the Internal Revenue Service (IRS) released much-anticipated guidance in Notice 2023-80 (Notice) announcing their intention to issue proposed...more

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