Tax News
Bringing you the latest tax and accounting updatesIRS – Tax Tips
- Final Regulations Issued on Allocation of Partnership Liabilities Under Section 752by Richard M. Corn, Martin T. Hamilton, Christine Harlow, Arnold P. May, Janicelynn Asamoto Park, Stuart Rosow, Kathleen R Semanski, Rita N. Halabi and Mary McNicholas on February 12, 2025 at 11:05 pm
Introduction On December 2, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations (the “Final Regulations”) on section 752[1] regarding the allocation of partnership recourse liabilities in situations in which multiple partners and related parties bear part or all of the economic risk of loss (“EROL”)...
- Summary of Tax Proposals in Leaked Document Detailing Policy Proposalsby Robert A. Friedman, Rita N. Halabi, Martin T. Hamilton, Christine Harlow, Malcolm Hochenberg, Mary McNicholas, David S. Miller and Amanda H. Nussbaum on February 12, 2025 at 7:58 pm
I. Introduction On January 17, 2025, news sources reported that Republican members of Congress circulated a detailed list of legislative policy options, including tax proposals. This blog post summarizes some of the tax proposals and corresponding revenue estimates mentioned in the list. II. Individuals (a) SALT Reform Options The $10,000 cap on the deductibility of...
- BlueCrest – the Court of Appeal considers Condition B of the salaried members rulesby Charlotte Ahamed, Catherine Sear and Robert E. Gaut on January 28, 2025 at 2:10 pm
The Court of Appeal has remitted the case of BlueCrest Capital Management (UK) LLP (BlueCrest) v HMRC back to the First-tier Tribunal (FTT) regarding the application of the UK’s salaried members rules (the Rules) to certain members of BlueCrest, an asset manager engaged in the provision of hedge fund management services, following a finding that...
- Tax Proposals Potentially Being Considered by the U.S. House Budget Committee in Reconciliationby Martin T. Hamilton, Amanda H. Nussbaum, Stuart Rosow, Christine Harlow and Carrie Slaton on January 27, 2025 at 10:11 pm
On January 17, 2025, multiple news outlets and other sources reported the existence of a memorandum circulated by the U.S. House of Representatives Budget Committee to the House Republican Caucus (the “Memorandum”) containing an extensive list of budget proposals that may be considered in connection with the new Congress’s widely expected budget reconciliation legislation. The...
- Trump Administration Disavows the OECD Global Tax Dealby Martin T. Hamilton, Richard M. Corn, Robert A. Friedman, David S. Miller, Amanda H. Nussbaum, Janicelynn Asamoto Park and Stuart Rosow on January 22, 2025 at 7:40 pm
On January 20, 2025, the White House issued a memorandum (the “Memorandum”)[1], announcing that the “Organization for Economic Co-operation and Development (OECD) Global Tax Deal” (the “Global Tax Deal”) has “no force or effect in the United States” and disavowing “any commitments” previously made by the United States with respect to the Global Tax Deal,...
- Tax Court Reaffirmed Soroban’s Holding that Active Limited Partners of State Law Limited Partnerships May Be Subject to Self-Employment Taxby Richard M. Corn, Robert A. Friedman, Arnold P. May, David S. Miller, Amanda H. Nussbaum, Rita N. Halabi and Mary McNicholas on January 2, 2025 at 6:07 pm
On December 23, 2024, in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), the Tax Court reaffirmed its earlier ruling in Soroban Capital Partners LP v. Commissioner (161 T.C. No. 12.) that active limited partners of a state law limited partnership are not entitled to the “limited partner exception” to self-employment tax for purposes...
- IRS Creates Standardized Form for Section 83(b) Electionsby Jesse T. Foley, Colleen Hart, Nicholas LaSpina, David B. Teigman, Kyle J. Litfin and Amanda H. Nussbaum on November 18, 2024 at 4:19 pm
Earlier this month, the Internal Revenue Service (“IRS”) released Form 15620, which is an approved IRS form for making Internal Revenue Code (“Code”) Section 83(b) elections. By way of background, Code Section 83(b) provides taxpayers with the ability to include the fair market value of nonvested property over the amount (if any) paid for the...
- Post Election – Expect Tax Legislationby Robert A. Friedman, Richard M. Corn, Jean Bertrand, Amanda H. Nussbaum and Martin T. Hamilton on November 13, 2024 at 12:57 pm
I. Introduction With clear Republican victories in the White House and the Senate, and a very slim majority for either side in the House of Representatives, we can expect tax legislation in the coming year. It is expected that the President elect will likely seek to enact his economic agenda as quickly as possible. While...
- Taxing carried interest in the UK: the new regime announced in the Labour government’s Autumn Budget 2024by Catherine Sear and Frazer Money on November 12, 2024 at 1:49 pm
On Wednesday 30 October 2024, the UK government announced changes to the UK taxation of carried interest as part of the 2024 Autumn Budget. Changes were expected following statements made by the Labour Party in the run up to their July 2024 general election win, including in their manifesto, and HM Treasury’s (HMT) subsequent call...
- Increase in Tax Audits of Use of Private Aircraft, a/k/a “Corporate Jets”by Richard M. Corn, Robert A. Friedman, Mitchell Gaswirth, Martin T. Hamilton, Stephanie Heilborn, Malcolm Hochenberg, David S. Miller, Amanda H. Nussbaum and Jay Waxenberg on October 28, 2024 at 3:08 pm
The IRS has announced a new audit campaign targeted at the use of private aircraft, a/k/a “corporate jets”. This has been an intensifying area of focus by the IRS over the last few years as a result of recently-increased tax benefits for private aircraft. Clients who use airplanes for business and have taken advantage of...
- Tax Proposals Potentially Being Considered by the U.S. House Budget Committee in Reconciliationby Martin T. Hamilton, Amanda H. Nussbaum, Stuart Rosow, Christine Harlow and Carrie Slaton on January 27, 2025 at 10:11 pm
On January 17, 2025, multiple news outlets and other sources reported the existence of a memorandum circulated by the U.S. House of Representatives Budget Committee to the House Republican Caucus (the “Memorandum”) containing an extensive list of budget proposals that may be considered in connection with the new Congress’s widely expected budget reconciliation legislation. The...
- Trump Administration Disavows the OECD Global Tax Dealby Martin T. Hamilton, Richard M. Corn, Robert A. Friedman, David S. Miller, Amanda H. Nussbaum, Janicelynn Asamoto Park and Stuart Rosow on January 22, 2025 at 7:40 pm
On January 20, 2025, the White House issued a memorandum (the “Memorandum”)[1], announcing that the “Organization for Economic Co-operation and Development (OECD) Global Tax Deal” (the “Global Tax Deal”) has “no force or effect in the United States” and disavowing “any commitments” previously made by the United States with respect to the Global Tax Deal,...
- Tax Court Reaffirmed Soroban’s Holding that Active Limited Partners of State Law Limited Partnerships May Be Subject to Self-Employment Taxby Richard M. Corn, Robert A. Friedman, Arnold P. May, David S. Miller, Amanda H. Nussbaum, Rita N. Halabi and Mary McNicholas on January 2, 2025 at 6:07 pm
On December 23, 2024, in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), the Tax Court reaffirmed its earlier ruling in Soroban Capital Partners LP v. Commissioner (161 T.C. No. 12.) that active limited partners of a state law limited partnership are not entitled to the “limited partner exception” to self-employment tax for purposes...
- Increase in Tax Audits of Use of Private Aircraft, a/k/a “Corporate Jets”by Richard M. Corn, Robert A. Friedman, Mitchell Gaswirth, Martin T. Hamilton, Stephanie Heilborn, Malcolm Hochenberg, David S. Miller, Amanda H. Nussbaum and Jay Waxenberg on October 28, 2024 at 3:08 pm
The IRS has announced a new audit campaign targeted at the use of private aircraft, a/k/a “corporate jets”. This has been an intensifying area of focus by the IRS over the last few years as a result of recently-increased tax benefits for private aircraft. Clients who use airplanes for business and have taken advantage of...
- No Money? No Problem: Recent IRS Favorable Guidance Regarding a REIT’s First Yearby Amanda H. Nussbaum, David S. Miller, Robert A. Friedman, Jean Bertrand, Muhyung (Aaron) Lee, Martine Seiden Agatston and Thomas Multari on October 10, 2024 at 11:21 pm
On October 4, 2024, the Internal Revenue Service (the “IRS”) released Private Letter Ruling 202440007, which concluded that the lack of income and assets in the first taxable year of an entity that had elected to be treated as a real estate investment trust (“REIT”) did not cause the entity to fail to qualify as...
A Primer On Education Tax Credits
When preparing for college, students and parents can easily list the costs like tuition, fees, supplies and room and board. But do you spend enough time considering the tax benefits associated with a college education? Lucky for you there are a number of education tax...