The (Po)Seiden Adventure

The early ‘70s saw a spate of so-called “disaster movies,” which involved burning skyscrapers, dysfunctional airports and, perhaps the most memorable of all, a cruise ship hit by a mammoth rogue wave that turned the ship over, forcing the passengers to make their way up to the hull.

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Final Partnership Audit Regulations May Impact Exempt Organizations

In the waning days of 2018, the IRS released final regulations on the new partnership audit rules under the Bipartisan Budget Act of 2015 (BBA). While these rules are typically thought of in the for-profit context, they can have a significant impact on exempt organizations whose investment portfolios include alternatives.

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Department of the Treasury Announces 2018 - 2019 Priority Guidance Plan

Following the enactment of Tax Reform, practitioners have been anxiously awaiting the announcement of the 2018-2019 Priority Guidance Plan to see what guidance has been prioritized.

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C Corporation vs. Pass-Through

The Rush to C Corporation that Wasn’t

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IRS’s Proposed Estate Tax “Clawback” Regulations

In November 2017, the IRS released proposed regulations clarifying the estate tax treatment of large lifetime gifts made now, while the federal estate and gift tax exemption is temporarily increased thanks to the Tax Cuts and Jobs Act of 2017.  These proposed regulations, if they go into effect as drafted, provide an opportunity for wealthy taxpayers to lock in the temporarily increased exemption by making large lifetime gifts.

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