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Ryan J. Dobens
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2025
Final regulations classify certain partnership related-party basis adjustment transactions as transactions of interest that require IRS information reporting
IRS and Treasury Department announce intent to withdraw regulations that identified partnership related party basis-shifting transactions as transactions of interest and waive corresponding disclosure penalties
Senate Finance changes to tax reconciliation bill would expand small business stock exclusion under IRC Section 1202
Tax reconciliation legislation will significantly affect individual taxpayers
Final tax reconciliation bill expands small business stock exclusion under IRC Section 1202
Final budget reconciliation law makes several changes affecting pass-through entities
IRS creates safe harbor allowing certain exchange-traded trusts to stake digital assets
Prop. regs. would make permanent safe harbor for furnishing information on Sec. 751 property
2024
Staffing agency satisfied qualified-trade-or-business requirement for purposes of IRC Section 1202 gain exclusion
Proposed regulations would apply disallowance and deferment rules at the partnership level for certain transactions
Court found stock transferred to a taxpayer was not qualified small-business stock, but left open the possibility of other shares remaining eligible
Treasury and IRS issue guidance on certain partnership related-party basis adjustment transactions
IRS releases Draft Form 7217 and instructions for reporting property distributed by a partnership
Final regulations address allocation of partnership recourse liabilities
IRS again provides partnerships with additional time to furnish information on IRC Section 751 property
Section 1202 And Partnerships
2023
IRS releases draft 2023 instructions to Schedule K-1 of Forms 1065 and 1120-S requiring new qualified small-business stock disclosures under IRC Sections 1045 and 1202
2021
Building Back Biden’s American Start-Up
Building Back Biden’s American Start-Up Through Tax Incentives