Ideas & Insights

Bill would treat carried interest as ordinary income and subject to it to self-employment tax, regardless of the holding period.

Final section 864(c)(8) regulations clarify rules for foreign partners with ECI from transfers of partnership interests.

As businesses renegotiate debts in the aftermath of COVID-19, it is critical to understand whether the debt is considered publicly traded.

The CARES Act provides business and tax relief to portfolio companies and investors. However, affiliation rules could limit SBA loan relief.