On Jan. 14, 2025, the Treasury Department issued final regulations designating certain related-party partnership basis shifting transactions as “transactions of interest.” Although this designation does not affect the substantive tax characterization of these transactions, it imposes significant reporting requirements on taxpayers and their advisors.
With law firms continuing to face heightened market and industry pressures, business development is essential for both law firm growth and individual lawyer success. However, coaching lawyers to become effective rainmakers presents unique challenges.
With a growing number of firms moving to a two-tier partnership structure, the question becomes what comes next for the dwindling number of major firms that don't have a nonequity tier. At what point do tradition and culture yield to change and progression?
The proposed regulations would disallow basis adjustments in many non-abusive scenarios where those basis adjustments are necessary to achieve tax results that correspond to economic reality.
Business owners, among their numerous tasks, should seek to minimize income taxes as they would any other expense, of course accommodating to the extent necessary the needs of their business. In this regard, building a documentary record to support the various tax positions being taken may preserve an income tax deduction that otherwise would be lost
The past decade has brought a significant rise in internal conflict within partnerships. Partners are wielding their autonomy to speak out (often forcefully) in favor of or opposition to broader firm decisions. This dynamic is leaving many law firms at a disadvantage.
Amid unprecedented billing rate hikes and an escalation of the battle for rainmaking talent, Am Law 100 law firms again raised the stakes on partner pay last year. At the same time, the average spread among Second Hundred firms fell a bit.
For a long time, the formula for law firm leverage was simple: grow the base of the pyramid by hiring more associates, keep them busy, and profit. But in recent years, that arithmetic is looking more like calculus as expanding nonequity partner tiers increasingly contribute to the law firm leverage equation.
While growing by acquiring lateral partners and practice groups can be lucrative, it carries many risks. Lateral candidates' projections of the revenue they will bring to a new firm can prove inaccurate, or a particular candidate may simply be a bad fit culturally.
Last year saw a "staggering" jump in the number of law firm leaders who said they wanted to increase their nonequity tier going forward. Now it's clear many of the biggest Big Law players are following through, with several Am Law 100 firms growing their income partner ranks by double-digit percentages in 2023.
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