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U.S. Treasury Partnerships Partnership Interests

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

Allen Matkins

Final Regulations Released for Partnership Recourse Liabilities

Allen Matkins on

On December 2, 2024, the Department of Treasury published final regulations (Final Regulations) governing the allocation of recourse liabilities of a partnership among its partners under Section 752 of the Internal Revenue...more

Goodwin

Highlights From The Final Carried Interest Regulations

Goodwin on

On January 7, 2021, the U.S. Treasury Department and the Internal Revenue Service released final regulations under Section 1061 of the Internal Revenue Code of 1986, as amended (“the Code”). The Final Regulations address the...more

Proskauer - Tax Talks

Section 1061 Final Regulations on the Taxation of Carried Interest

Proskauer - Tax Talks on

On January 7, 2021, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations (the “Final Regulations”) providing guidance on Section 1061 of the Internal...more

McDermott Will & Schulte

IRS Issues Final Regulations Concerning Withholding on Partnership Interest Transfers

McDermott Will & Schulte on

The US Department of the Treasury and Internal Revenue Service (IRS) recently issued final regulations under section 1446(f), a provision enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA) that generally imposes a...more

Proskauer - Tax Talks

Section 1446(f) Final Regulations: Key Changes to Guidance on Non-Publicly Traded Partnership Interest Transfers by Non-U.S....

Proskauer - Tax Talks on

On October 7, 2020, the U.S. Internal Revenue Service (“IRS”) and Treasury Department released final regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions...more

Neal, Gerber & Eisenberg LLP

Fund Managers and Family Offices Get Some Clarity on Carried Interests with Issuance of Proposed Treasury Regulations

On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more

Nutter McClennen & Fish LLP

Treasury Issues Final Regulations on Section 721(c) Partnerships

As you probably know, a taxpayer realizes gain when the taxpayer transfers appreciated property in exchange for other property. There are exceptions to this general rule. One of those exceptions is defined in Internal Revenue...more

Nutter McClennen & Fish LLP

Partnership Transactions and Bonus Depreciation: A Narrow Path

The recently issued bonus depreciation regulations should influence – but not control – how we structure certain partnership contributions and distributions. These transactions include partnership mergers and divisions....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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