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May 27, 2024 | 
mondaq.com | David Salamon |Gregg M. Benson |Timothy Santoli |Helen Huang
On April 12, 2024, the Treasury Department and Internal Revenue
Service (IRS) issued proposed Treasury Regulations (REG-115710-22) providing
comprehensive guidance for applying the one-percent excise tax owed
on corporate stock repurchasesoccurring on or after January 1, 2023
(Stock Buyback Excise Tax).
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May 23, 2024 | 
lexology.com | David Salamon |Gregg M. Benson |Timothy Santoli |Helen Huang
IntroductionOn April 12, 2024, the Treasury Department and Internal Revenue Service (IRS) issued proposed Treasury Regulations (REG-115710-22) providing comprehensive guidance for applying the one-percent excise tax owed on corporate stock repurchasesoccurring on or after January 1, 2023 (Stock Buyback Excise Tax).
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Jul 26, 2023 | 
mondaq.com | Timothy Santoli
Sponsors of investment partnerships should be aware that the IRS
is aggressively challenging management structures designed to
qualify for the limited partner exclusion from tax under the
Self-Employment Contribution Act ("SECA").
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Jul 25, 2023 | 
natlawreview.com | Timothy Santoli
Sponsors of investment partnerships should be aware that the IRS is aggressively challenging management structures designed to qualify for the limited partner exclusion from tax under the Self-Employment Contribution Act (“SECA”).
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Jul 24, 2023 | 
lexology.com | Timothy Santoli
Sponsors of investment partnerships should be aware that the IRS is aggressively challenging management structures designed to qualify for the limited partner exclusion from tax under the Self-Employment Contribution Act (“SECA”).
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Jul 19, 2023 | 
mondaq.com | Timothy Santoli
A recent US Tax Court decision confirmed that taxpayers can
benefit from the "profits interest" safe harbor, set
forth in Revenue Procedures 93-27 and 2001-43, which holds that the
issuance of such an interest in exchange for services that benefit
a lower-tier entity that is or would become a partnership is not a
taxable event. The Tax Court also rejected the IRS's assertion
that the purported profits interest was actually a capital
interest.
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Jul 18, 2023 | 
natlawreview.com | Timothy Santoli
A recent US Tax Court decision confirmed that taxpayers can benefit from the “profits interest” safe harbor, set forth in Revenue Procedures 93-27 and 2001-43, which holds that the issuance of such an interest in exchange for services that benefit a lower-tier entity that is or would become a partnership is not a taxable event. The Tax Court also rejected the IRS’s assertion that the purported profits interest was actually a capital interest.
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Jul 18, 2023 | 
lexology.com | Timothy Santoli
A recent US Tax Court decision confirmed that taxpayers can benefit from the “profits interest” safe harbor, set forth in Revenue Procedures 93-27 and 2001-43, which holds that the issuance of such an interest in exchange for services that benefit a lower-tier entity that is or would become a partnership is not a taxable event. The Tax Court also rejected the IRS’s assertion that the purported profits interest was actually a capital interest.
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Jul 13, 2023 | 
mondaq.com | Timothy Santoli |David Salamon
The Internal Revenue Service (the "IRS"), in private
letter ruling 202308010 ("PLR"), held that success-based
fees were incurred by a private equity ("PE") sponsor
(i.e., the seller) rather than by the target (i.e., a subsidiary of
the PE sponsor) and therefore denied the target's request for
relief for a late election under Revenue Procedure 2011-29 to
deduct 70% of the success-based fees (the "Safe Harbor
Election").
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Jul 11, 2023 | 
natlawreview.com | Timothy Santoli
The Internal Revenue Service (the “IRS”), in private letter ruling 202308010 (“PLR”), held that success-based fees were incurred by a private equity (“PE”) sponsor (i.e., the seller) rather than by the target (i.e., a subsidiary of the PE sponsor) and therefore denied the target’s request for relief for a late election under Revenue Procedure 2011-29 to deduct 70% of the success-based fees (the “Safe Harbor Election”).
