By: Amanda Wilson At a tax conference yesterday, a Treasury official indicated that Treasury is working hard to finalize regulations before the 60-day freeze that occurs before the inauguration of a new president (Treasury will not issue final...

By: Amanda Wilson The IRS recently released IRS legal memorandum 201606027. In this memorandum, the IRS considered the impact of a bad boy guarantee on allocating partnership liabilities under Section 752. Traditionally, bad boy guarantees have not...

There was an interesting article in yesterday's Wall Street Journal about the difficulties facing an overhaul of the tax system. The article can be found here.

By: Amanda Wilson The Foreign Investment in Real Property Tax Act (FIRPTA) subjects foreign sellers to U.S. tax when they sell their interest in real property located in the U.S., including interests in companies that predominately hold real estate....