Weil Tax BLOG - Feed https://tax.weil.com/category/partnership-interests/ Views and developments from the Tax Department at Weil Fri, 29 May 2026 16:24:17 +0000 hourly 1 IRS Issues Final Regulations on Disclosure of Partnership Related-Party Basis Adjustment Transactions https://tax.weil.com/insights/irs-issues-final-regulations-on-disclosure-of-partnership-related-party-basis-adjustment-transactions/ Wed, 29 Jan 2025 20:01:11 +0000 Robert Frastai Lauren Gorsche https://tax.weil.com/?p=2437 On January 14, 2025, the U.S. Treasury Department and IRS published final regulations (T.D. 10028) (the “Final Regulations”) classifying certain partnership related-party basis adjustment transactions (and substantially similar transactions) as “transactions of interest” (TOIs), a type of reportable transaction subject to disclosure. Unfortunately, the Final Regulations as drafted apply to certain ordinary course commercial transactions

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]]> Practical PFIC Considerations in Connection with SPACs https://tax.weil.com/legal-developments/practical-pfic-considerations-in-connection-with-spacs/ Thu, 15 Apr 2021 01:51:00 +0000 Devon Bodoh Joseph Pari https://tax.weil.com/?p=1271 A number of practical considerations must be taken into account in connection with the formation and operation of a non-U.S. special purpose acquisition company (“SPAC”) to mitigate the potential risk of the non-U.S. SPAC being treated as a passive foreign investment company (“PFIC”) for U.S. federal income tax purposes. Generally speaking, a non-U.S. corporation is

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]]> Final 1061 Regulations https://tax.weil.com/whats-new-on-the-blog/final-1061-regulations/ Mon, 11 Jan 2021 23:59:12 +0000 Robert Frastai http://tax.weil.com/?p=1151 On January 7, 2021, the IRS and Treasury Department issued final regulations (T.D. 9945) under Section 1061 of the Internal Revenue Code of 1986, as amended (the “Code”, and such regulations, the “Final Regulations”) detailing, among other things, how long-term capital gain may be recharacterized as short-term capital gain in respect of carried interest arrangements

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]]> Final Section 864(c)(8) Regulations – Some Relief for Certain Non-U.S. Partners https://tax.weil.com/legal-developments/final-864c8-regulations-some-relief-for-certain-non-u-s-partners/ Fri, 25 Sep 2020 13:41:29 +0000 Devon Bodoh Robert Frastai Carlos Parra http://tax.weil.com/?p=1063 On September 21, 2020, the IRS finalized regulations (the “Final Regulations”) under section 864(c)(8) of the Internal Revenue Code (the “Code”). The Final Regulations generally impact foreign partners in partnerships engaged in a U.S. trade or business and generally retain the approach of proposed regulations that were issued on December 20, 2018 (REG-113604-08) (the “Proposed

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