Robert Frastai

• IRS Issues Final Regulations on Disclosure of Partnership Related-Party Basis Adjustment Transactions Blog Post — Tax Blog — By Robert Frastai and Lauren Gorsche — January 30, 2025
  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 undertaken by private funds. While basis adjustments may be a feature of such a transaction, in our experience, private fund sponsors are motivated by economics and commercial deal terms rather than tax outcomes tied to tax basis adjustments. ...
• Chambers Expert Focus Weil Tax Insight Series: Tax Implications of New Rules Under the Advisers Act Blog Post — Tax Blog — By Robert Frastai and Andrew Morris — October 17, 2023

  In this edition of the Chambers Expert Focus Weil Tax Insight Series, Weil Tax partners Robert Frastai and Andrew Morris discuss the impact of the SEC’s recently adopted rules under the Investment Advisers Act of 1940 on certain tax structuring and compliance matters for private funds, including after-tax clawback obligations, blocker and withholding taxes that are allocated to

  The post Chambers Expert Focus Weil Tax Insight Series: Tax Implications of New Rules Under the Advisers Act appeared first on Weil Tax BLOG.

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