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A common cross-border reorganization can doom eligibility for the valuable gain exclusion without thoughtful planning.
Profits–interest partners frequently are allocated a share of the gain recognized in connection with a liquidity event. This allocation can lead to unexpected results related to Sec. 1245 recapture.
If tax-exempt entities invest in energy projects through partnerships, careful consideration should be given to allocations under the respective partnership arrangements to avoid any detrimental ...