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April 17, 2019 Dave Sobochan

IRS Releases Round 2 of Proposed Regulations Clarifying Qualified Opportunity Zone Program

The IRS and the U.S. Department of the Treasury released round two of proposed regulations surrounding the Qualified Opportunity (QO) Zone Program today. The 169-pages of regulations address many areas, including:How businesses headquartered in designated QO Zones may benefit,The timeline for QO...

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March 19, 2019 Matt Rager

The Intersection of Cryptocurrencies and Individual Taxation – Part I

While cryptocurrencies have become a popular investment vehicle, there is still much ambiguity regarding how to treat the emerging asset class for tax purposes. Taxation of cryptocurrencies is complicated at any level, be it partnership, corporation or other. However, it's also important to...

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December 19, 2018 Donna Weaver

Final Guidance Released on Partnership Representatives Under IRS Partnership Audit Rules

The Treasury has issued final regulations regarding the partnership representative designation and authority under the relatively new IRS partnership audit rules. These rules became effective for tax years beginning after December 31, 2017.   Most importantly, the regulations confirm the...

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August 31, 2017 Robert Velotta

The Impact of IRC Section 751 to MLP Investors

Generally, a partner who sells an interest in a partnership will recognize capital gain or capital loss on the disposition. However, Internal Revenue Code Section 751 may cause an unanticipated tax consequence — the need for the partner to recognize ordinary income on the sale of the...

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May 26, 2017 Robert Velotta

Monitoring Foreign Capital Gains Tax Exposure for RICs

The obligation for registered investment companies (RICs) to pay foreign capital gains tax is not new by any means, but it is gaining more attention lately, making it imperative for fund management to take note.   Foreign tax withholding on interest and dividends has been and continues to...

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