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New Partnership Audit Rules Heading Our Way??

By Amanda Wilson on Oct 28, 2015 in audit, government, International, IRS, Partnership Tax, Tax

By:  Amanda Wilson The budget bill introduced yesterday includes a proposal to revamp/streamline how partnerships are audited.  Specifically, it would repeal the  much maligned TEFRA (1982 Tax Equity and Fiscal Responsibility Act) rules. The overall...

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...

Obama Renews Carried Interest Fight

By Amanda Wilson on Sep 18, 2015 in carried interest, code, government, International, Obama care, Partnership Tax

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...

Further Crackdown on Offshore Corporations

By Amanda Wilson on Sep 2, 2015 in Foreign Operations, International, IRS, Partnership Tax, treasury

By:  Amanda Wilson In their continued effort to crackdown on offshore activity, the IRS and Treasury released proposed regulations yesterday that target debt held by foreign partnerships.  These regulations provide that debt held by foreign...