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Electing into New Partnership Audit Rules

By Amanda Wilson on Feb 2, 2016 in audit, government, International, IRS, lowndes, Partnership Tax, treasury

By:  Amanda Wilson As previously discussed (here), TEFRA, the audit regime that has long applied to partnerships, has been repealed and a new partnership audit regime is poised to go into effect for tax years beginning in 2018.  The new audit rules...

Treasury Cracking Down on Secret Real Estate Sales

By Amanda Wilson on Jan 14, 2016 in Real estate, International, irc, IRS, LLC, Tax, treasury

By:  Amanda Wilson There was an interesting story this morning on CBS about the Treasury Department cracking down on secret real estate sales.  Going forward, buyers and sellers may be limited in their ability to hide behind limited liability...

Senators Call on IRS to Finalize Management Fee Waiver Regulations

By Amanda Wilson on Sep 23, 2015 in Congress, government, International, irc, IRS, medical marijuana, Partnership Tax, treasury

By:  Amanda Wilson Yesterday, Senators Franken, Warren, Baldwin and Whitehouse sent Treasury Secretary Lew a letter regarding management fee waiver arrangements. What is a management fee waiver arrangement?  It is where a fund manager waives its...

Carried Interests OK Under Management Fee Waiver Regulations

By Amanda Wilson on Sep 21, 2015 in carried interest, code, International, IRS, regulations, treasury

By:  Amanda Wilson Last week, I was at the ABA Tax Section meeting in Chicago.  During one of the partnership panels, Clifford Warren, Special Counsel to the Associate Chief Counsel (Passthroughs and Special Industries) at the IRS, was posed several...