Andrea Macintosh Whiteway
Highly Influential Citations0
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The Internal Revenue Service recently proposed regulations addressing the consequences of owning a partnership interest through a disregarded entity (such as a single-owner LLC) on the allocation of… Continue Reading
This article discusses a recent revenue ruling in which the IRS finally provided guidance addressing the issue of a partnership engaging in a like-kind exchange of leveraged property that straddles… Continue Reading
As a result of the tax rules relating to the qualification of the conduit entity as a REMIC, conduit loans generally prohibit prepayment but allow the loan to be defeased. This article explores the… Continue Reading
The authors analyze and suggest changes to the recently proposed regulations dealing with partnership debt-for-equity exchanges that, in their current form, would deny a tax loss for creditors.
The authors analyze the complex issues that arise in the application of section 108(i), the new cancellation of indebtedness deferral election, to partners and partnerships. In particular, because of… Continue Reading