A private letter ruling request is a request to the IRS by a taxpayer (an individual, business, or other entity) requesting the IRS to address, in writing, a specific tax situation that applies to the...
The ever-growing number of environmental laws has significantly affected real estate acquisitions. Nearly every purchase agreement will contain environmental representations and warranties, with the seller...
Environmental, social, and governance (ESG) remains an area of intense focus for private fund sponsors, private fund investors, and government regulators. Despite certain regulatory and political headwinds...
Representations and warranties insurance (also referred to as reps and warranties insurance, RWI, or R&W insurance) is designed specifically to cover losses resulting from unknown breaches for all...
Understand the role of ADR mechanisms in drug, medical device, biologics, and other life sciences agreements. Read now » Related Content Life Sciences Due Diligence Considerations in M&A...
Learn more about the tax restrictions and limitations on related-party transactions that apply to partnerships and other flow-through entities. Because partnership tax items generally flow through directly to partners/LLC members, and do not remain with the entity, certain transactions at the entity level can result in tax consequences that the Internal Revenue Code never intended. Consequently, the federal tax code appropriately limits and restricts the unintended tax effects of these inappropriate transactions.
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