The Consolidated Appropriations Act, 2018 (“Act”), was signed into law on March 23rd. The Act contains a number of changes to the partnership audit rules that went into effect for partnerships (including LLCs taxed as...
Read MoreTax reform is all the rage these days. The House and Senate released their respective proposals for tax reform with some sweeping changes to tax brackets, individual deductions, tax rates for certain owners of pass-throughs and...
Read MoreBy: Emily Dorisio The Fifth Circuit Court of Appeals recently affirmed that the devil really is in the details in a case that illustrates the importance of ensuring that deal documents accurately reflect the parties’ agreed upon...
Read MoreBy Emily Dorisio As we enter the giving season and begin making charitable contributions it is important to remember that some gifts require more than just the act of giving to qualify for a charitable tax deduction. For...
Read MoreBy Emily Dorisio The IRS issued a Memorandum on April 15, 2016 clarifying the treatment of nonrecourse debt subject to certain “bad boy” guarantees. The Memorandum takes a position contrary to the recent Chief Counsel Advice...
Read MoreBy Emily DorisioIt is common for LLCs operating (and taxed) as real estate partnerships to obtain nonrecourse financing secured only by the real estate owned by the LLC. Liabilities of an LLC taxed as a partnership are allocated...
Read MoreBy Emily Dorisio Recently issued proposed regulations provide guidance on how to determine when a distribution by a partnership (including LLCs taxed as partnerships) to a service partner is really a disguised payment for...
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