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What Is Carried Interest?

By Amanda Wilson on Oct 19, 2016 in carried interest, government, International, IRS, lowndes, medical marijuana, Partnership Tax, Tax

By:  Amanda Wilson During the second presidential debate, one of the few things that both candidates agreed on was doing away with carried interest as part of their proposed tax changes.  But they never explained what it is.  So what was is carried...

The End of Leveraged Partnership Transactions?

By Amanda Wilson on Sep 21, 2016 in IRS, medical marijuana

By:  Amanda Wilson If a partner contributes property to a partnership, and within a two year period, receives cash from that partnership, the tax rules generally treat that as a disguised sale of property by the partner to the partnership.  One...

IRS Reverses Position on Bad Boy Guarantees

By Amanda Wilson on Apr 19, 2016 in International, IRS, Tax

By:  Amanda Wilson As previously discussed (here), the IRS recently released a chief counsel advice memorandum that concluded that bad boy guarantees turned what would otherwise be a nonrecourse debt into a recourse debt for Section 752 purposes. ...

IRS Moving Forward With Private Debt Collection Program

By Amanda Wilson on Mar 9, 2016 in debt collection, fraud, government, identity theft, International, IRS, tax fraud

By:  Amanda Wilson IRS Commissioner John Koskinen recently announced that the IRS is moving forward with a program to have private companies enter into contracts to collect tax debts.    Commissioner Koskinen expected that the new private debt...