Tax Talks

The Proskauer Tax Blog

Tag Archives: Partnership Taxation

Senator Manchin Announces That He Will Not Support the Build Back Better Act – Where Things Stand Now

By David S. Miller, Muhyung (Aaron) Lee, Amanda H. Nussbaum, Arnold P. May, Dan Paulos and Martin T. Hamilton on Posted in BEAT, Corporate Taxation, financial products, GILTI, International Taxation, Mergers & Acquisitions, Partnership Taxation, Tax Reform, U.S. Legislation
Today, December 19, 2021, Senator Joe Manchin (D., W.Va.) said that he opposes the Build Back Better Act, which effectively prevents its passage.  While there are no immediate prospects for the Build Back Better Act to become law, future tax acts tend to draw upon earlier proposals.  With a view to future tax proposals, this … Continue Reading

Section 1446(f) Final Regulations: Key Changes to Guidance on Non-Publicly Traded Partnership Interest Transfers by Non-U.S. Persons

By Jeremy Naylor, Stephen Severo, Charles R. McGonigal and Kaitlyn L. Flynn-Rozanski on Posted in In the news, International Taxation, IRS, Partnership Taxation, Tax Cuts and Jobs Act, Tax Reform, Uncategorized
On October 7, 2020, the U.S. Internal Revenue Service (“IRS”) and Treasury Department released final regulations[1] providing guidance on the rules imposing withholding and reporting requirements under the Code[2] on dispositions of certain partnership interests by non-U.S. persons (the “Final Regulations”). The Final Regulations expand and modify proposed regulations[3] that were published on May 13, … Continue Reading

House of Representatives and Senate Conferees Reach Agreement on the Tax Cuts and Jobs Act (H.R. 1): Description of the Conference Agreement and Differences from House and Senate Versions

By Steven Einhorn, Martin T. Hamilton, Kathleen R Semanski, David S. Miller and Richard M. Corn on Posted in Corporate Taxation, Executive Compensation, International Taxation, Inversions, Partnership Taxation, Real Estate, Tax Cuts and Jobs Act, Tax Reform, U.S. Legislation
On Friday, December 15, the U.S. House of Representative and Senate conferees reached agreement on the Tax Cuts and Jobs Act (H.R. 1) (the “Final Bill”), and released legislative text, an explanation, and the Joint Committee on Taxation estimated budget effects (commonly referred to as the “score”).  Next week the House and Senate are each … Continue Reading
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