Weil Tax BLOG - Feed https://tax.weil.com/contributor/lauren-gorsche/ Views and developments from the Tax Department at Weil Tue, 05 May 2026 15:19:09 +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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]]> New Partnership Withholding Obligations Effective as of January 1, 2023 https://tax.weil.com/insights/new-partnership-withholding-obligations-effective-as-of-january-1-2023/ Fri, 06 Jan 2023 02:47:29 +0000 Robert Frastai Andrew Morris Lauren Gorsche https://tax.weil.com/?p=1819 Background In 2017, tax legislation was enacted to provide that (x) gain or loss derived by a non-US person on the sale or exchange of an interest in a partnership engaged in a U.S. trade or business is treated as effectively connected gain or loss and subject to U.S. tax (“ECI”) and (y) a transferee

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]]> Background In 2017, tax legislation was enacted to provide that (x) gain or loss derived by a non-US person on the sale or exchange of an interest in a partnership engaged in a U.S. trade or business is treated as effectively connected gain or loss and subject to U.S. tax (“ECI”) and (y) a transferee

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]]> New IRS proposed regulation would reverse longstanding IRS ruling and upend commonly used real estate fund structures https://tax.weil.com/insights/new-irs-proposed-regulation-would-reverse-longstanding-irs-ruling-and-upend-commonly-used-real-estate-fund-structures/ Wed, 04 Jan 2023 15:23:32 +0000 Devon Bodoh Robert Frastai Hillel N. Jacobson Andrew Morris Lauren Gorsche https://tax.weil.com/?p=1816 Shortly before the new year, the Internal Revenue Service (“IRS”) dropped a holiday bombshell on the tax community when it issued a proposed regulation under the Foreign Investment in Real Property Tax Act of 1980 (“FIRPTA”). The proposed regulation would, if enacted in its current form, reverse a longstanding IRS ruling interpreting FIRPTA (the “2009

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]]> Shortly before the new year, the Internal Revenue Service (“IRS”) dropped a holiday bombshell on the tax community when it issued a proposed regulation under the Foreign Investment in Real Property Tax Act of 1980 (“FIRPTA”). The proposed regulation would, if enacted in its current form, reverse a longstanding IRS ruling interpreting FIRPTA (the “2009

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]]> Certain Carried Interest Tax Changes in the Schumer – Manchin Tax Reconciliation Bill (Inflation Reduction Act of 2022) https://tax.weil.com/insights/certain-carried-interest-tax-changes-in-the-schumer-manchin-tax-reconciliation-bill-inflation-reduction-act-of-2022/ Thu, 28 Jul 2022 19:45:20 +0000 Robert Frastai Andrew Morris Lauren Gorsche https://tax.weil.com/?p=1692 On July 27, 2022, Senate Majority Leader Chuck Schumer and Senator Joe Manchin reached a deal on new legislation entitled the “Inflation Reduction Act of 2022” to be added to the fiscal year 2022 budget reconciliation bill. President Biden issued a statement of support shortly after its announcement. The significant tax changes to the treatment

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]]> Potential Tax Impact of Proposed SEC Regulations https://tax.weil.com/latest-thinking/potential-tax-impact-of-proposed-sec-regulations/ Fri, 11 Mar 2022 06:45:00 +0000 Robert Frastai Andrew Morris Lauren Gorsche https://tax.weil.com/?p=1579 On February 9, 2022, the Securities and Exchange Commission (SEC) proposed new rules that, if implemented, would have profound effects on the private equity industry and the relationship among the SEC, fund advisers and investors (the SEC Proposal).1 The proposed rules would prohibit private fund advisers from engaging in certain activities, regardless as to whether

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