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...

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...

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 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...