Sarah Rizzo

Jun 25, 2024 | lexology.com | Trevor Allen |Edward Gonzalez |Kathleen Gregor |Sarah Rizzo |Jeff Romero |Paul Schockett | +1 more

On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships: In new proposed regulations, the IRS identified several transactions as “transactions of interest,” which would require taxpayers and material advisors to report such transactions to the IRS.1 Notice 2024-54 describes two sets of forthcoming proposed regulations that would have the effect of (i) suspending the basis-adjustment benefits of...

May 11, 2023 | lexology.com | Nickolas Gianou |Nathan Giesselman |Kathleen Gregor |Shalom Huber |Sarah Rizzo |Paul Schockett | +2 more

On May 3, 2023, the U.S. Tax Court upheld a taxpayer’s reliance on Revenue Procedure 93-27 to characterize as a profits interest a partnership interest granted in exchange for services that were provided indirectly for the benefit of an operating partnership in a tiered partnership context. ES NPA Holding LLC v. Commissioner, T.C. Memo 2023-55 (May 3, 2023).

Mar 3, 2023 | casualphotophile.com | Sarah Rizzo |Josh Solomon

Kodak Portra 400 is the most popular color film on the market today, so popular that it’s become near synonymous with modern color film photography – and for good reason. It’s a highly versatile, professional-grade film with wide exposure latitude, modern grain structure, and warm pleasing tones. But, it’s no secret that shooting color film, especially professional-grade Kodak color film, like Portra, has become significantly more expensive over the past couple of years.