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U.S. Treasury Capital Losses

Holland & Knight LLP

Proposed Rule Modifies Timing of "Hot Asset" Reporting

Holland & Knight LLP on

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

Robins Kaplan LLP

Financial Daily Dose 10.31.2019 | Top Story: Fed Delivers Expected Interest Rate Cut

Robins Kaplan LLP on

As universally expected, the Fed’s Open Market Committee delivered its third interest rate cut of 2019 yesterday, though it did so while signaling that it’s likely to pause before taking action again and “is now shifting into...more

Latham & Watkins LLP

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

Latham & Watkins LLP on

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

Eversheds Sutherland (US) LLP

Required Summer Reading: Guidance Issued on the Tax Treatment of Guaranteed Minimum Benefit Hedges and Identified Mixed Straddles

The Treasury and the IRS offered two pieces of highly anticipated guidance on July 18 that are particularly relevant to the life insurance industry. ...more

McDermott Will & Emery

Treasury Finalizes Regulations on Noncompensatory Partnership Options

McDermott Will & Emery on

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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