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...

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 common...

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....

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...