By: Amanda Wilson As my prior blog posts have discussed (see most recent here), we are seeing repeated efforts to disallow favorable tax treatment of carried interests in partnership. Earlier this week, President Obama once again called for Congress...

By: Amanda Wilson I'm at the ABA Tax conference this week and one of this morning's first panels included a discussion of hot topics in partnerships. Curtis Wilson, IRS Associate Chief Counsel in Passthroughs and Special Industries, discussed the...

By: Amanda Wilson The IRS issued guidance on Tuesday dealing with first-year bonus depreciation. The Tax Increase Prevention Act of 2014 amended Section 168(k)(2) by extending the one year placed-in-service date for property that qualifies for 50...

By: Amanda Wilson On Monday, the IRS released Notice 2015-59. In it, the IRS announced that the IRS will no longer issue private letter rulings on whether a distribution satisfies the requirements of Section 355 for a tax-free spin-off where (i) the...