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U.S. Treasury › Capital Losses › Internal Revenue Code (IRC)

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

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

Eversheds Sutherland (US) LLP on

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

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