The allocations that partners establish in their partnership agreement determine each partner's distributive share. A partner’s distributive share is that fraction of a partnership's items of income, gain, loss, deduction, and credit that the partnership...
As we step into the new year, it's a great time to reflect on any changes in partnership interests that took place in 2024. The sale or exchange of a partnership interest is only one way in which partnership interests can change. For example, if a partner,...
With Republican control of the White House, the Senate, and the House of Representatives, President-elect Donald J. Trump is expected to support a wide range of policies including raising tariffs and lowering taxes. Possibilities include $2 trillion in tax cuts...
The Inflation Reduction Act provided special funding to the IRS, much of it targeted for IRS enforcement efforts. While funding for this effort was originally appropriated at $45.6 billion, a subsequent Congress reduced the amount by about $20 billion. The IRS...
The Department of the Interior's (DOI's) Payments in Lieu of Taxes (PILT or PILOT) program, is a federal initiative that offsets the loss of property tax revenue for local governments due to the presence of nontaxable federal lands within their jurisdictions...
Many tax-related ballot issues were raised across all 50 U.S. states and the District of Columbia for the 2024 election year. The issues spanned measures related to income tax, sales and use tax, property tax, and miscellaneous taxes, put out there for voter approval...
The 2024 landmark case , Loper Bright Enters. v. Raimondo, 144 S. Ct. 2244 (June 28, 2024) , officially jettisoned the 40-year-old Chevron two-step standard for statutory interpretation. Will Loper Bright motivate the Treasury Department and IRS to now avoid formal...
Publicly traded companies can offer their employees access to purchase employer stock on a discounted basis, using an employee stock purchase plan that complies with I.R.C. § 423 . These plans are broad-based programs that, during an “offering period”...
NIL rights refer to the ability of student-athletes to earn compensation for the use of their name, image, and likeness. This includes activities such as endorsement deals and social media promotions, allowing student-athletes to monetize their personal brand....
A listed transaction is a transaction that is the same as or substantially similar to one of the types of transactions the IRS has determined to be a tax avoidance transaction and identified as such by notice, regulation, or other form of published guidance. It...
Liquidating distributions are the distributions through which a partnership or limited liability company (LLC) terminates a partner's or a member's interest in the entity. Like current distributions, liquidating distributions are generally tax-free—in...
A “G” reorganization is a specific category of I.R.C. § 368 reorganization intended to facilitate the restructuring or rehabilitation of a distressed corporation in a Title 11 bankruptcy case. A "G" reorganization requires the transfer...
When tax-exempt or non-U.S. taxpayers invest in U.S. businesses, unwanted and unintended U.S. tax obligations can follow without careful planning. Blocker corporations have become a common strategy employed by private equity (PE) funds, particularly in buyout transactions...
Private equity transactions refer to investments (and the sale or disposition of those investments) made by pooled investment vehicles (a private equity fund, venture fund, or other group of institutional investors) in the non-publicly traded securities issued...
With more than $4 trillion of tax increases scheduled to take effect at the end of 2025, given the sunsetting provisions of the Tax Cuts and Jobs Act (TCJA), 2025 will be the most consequential year for tax legislation since the 2017 enactment of the TCJA. Whatever...