Transactions involving the disposition of partnership property or partnership interests can trigger rules that limit business interest expense deductions. Section 163(j) of the Internal Revenue Code generally...
Interested in knowing what other partners are saying about how commercial lease agreements are evolving? Access exclusive market intelligence about private commercial lease agreements, as only told by...
The seller usually wants assurances that a buyer will be able to fund an acquisition at the closing, particularly if the closing is subject to a lengthy interim period between signing and closing. If a...
A company that receives a warning letter from the Food and Drug Administration (FDA) is on FDA's radar screen. In addition to responding appropriately to any actual or potential violations indicated...
We just added Arbitration Q&A content to Practical Guidance’s State Law Comparison Tool! Compare state laws on arbitration both pre-dispute and once a dispute arises across five key arbitration...
The Treasury and IRS issued proposed regulations under I.R.C. Section 951A providing guidance on passive foreign investment companies (PFICs) and controlled foreign corporations (CFCs) held by domestic partnerships and S corporations. 87 Fed. Reg. 3,890 (Jan. 25, 2022). The proposed rules impact PFIC reporting and determine that domestic partnerships and S corporations should be treated as entities or aggregates of their partners and shareholders, respectively, for purposes of making qualified electing fund (QEF) or mark-to-market (MTM) elections, recognizing QEF inclusions or MTM amounts, or filing Forms 8621.
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