Aug. 05, 2020 - The IRS recently released long-awaited final regulations (Final Regulations) on the limitation on the deductibility of interest expenses under section 163(j), along with new proposed regulations (New Proposed Regulations) that address a variety of highly technical issues that are not covered by...
Presentation: New IRS Partnership Audit Rules for Tax Counsel: Preparing for Massive Changes
This presentation discusses the far-reaching aspects of the new partnership audit rules provided by the Bipartisan Budget Act of 2015 and how this legislation will affect the formation and operations of partnerships, as well as the disposition of partnership interests and admission of new partners. Heath Martin presented this as part of an expert panel that provided a critical look at the impact of this law. His presentation offers insights on how to address changes brought about by the new audit processes and identifies commercial and operational concerns arising from the legislation.
July 22, 2020 - The U.S. Treasury Department and the IRS have released final regulations (2020 Final Regulations) allowing certain domestic shareholders of a “controlled foreign corporation” (CFC) to elect under a high-tax exception to opt out of the tax imposed on the CFC’s “global intangible low-taxed...