Searching Content indexed under Tax Authorities by Patrick McCurry ordered by Published Date Descending.
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The IRS Releases CCA 201606027
Below is a basic description of the rules regarding the allocation of partnership liabilities among partners and a summary of the 2016 CCA.
United States
24 Mar 2016
Proposed Regulations Require Significant Entrepreneurial Risk For A Service Partner's Income To Be A Distributive Share
On July 22, 2015, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released proposed regulations under Section 707(a)(2)(A) (the proposed regulations) which would treat certain partnership distributions as disguised payments for services taxable as ordinary income.
United States
19 Aug 2015
Treasury Finalizes Regulations On Noncompensatory Partnership Options
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 option is, in substance, an interest in the issuing partnership.
United States
4 Mar 2013
Supreme Court Holds Six-Year Statute Of Limitations Does Not Apply To Overstatement Of Basis
On April 25, 2012, the Supreme Court of the United States affirmed the U.S. Court of Appeals for the Fourth Circuit’s decision in "Home Concrete & Supply, LLC v. United States", 634 F.3d 249 (4th Cir. 2011), and held that an overstatement of basis does not constitute an omission from gross income that is subject to the six-year statute of limitations period under section 6501(e)(1)(A).
United States
2 May 2012
Carried Interest Language Narrowed, But Remains Far-Reaching
This newsletter summarizes the Obama administration’s recent carried interest tax provision.
United States
29 Sep 2011
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