On May 28, 2025, in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) (“Soroban II”), the Tax Court held the active role of limited partners in a fund manager caused them to fail to qualify as “limited partners”...more
Senator Thom Tillis introduced a bill (called the “Tackling Predatory Litigation Funding Act”) that would impose additional significant taxes on litigation funding investments. Rep. Kevin Hern (R-OH) introduced a similar bill...more
On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more
3/5/2025
/ Compliance ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Liquidation ,
Partnerships ,
Penalties ,
Regulatory Agenda ,
REIT ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
On December 2, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations (the “Final Regulations”) on section 752 regarding the allocation of partnership...more
On January 17, 2025, multiple news outlets and other sources reported the existence of a memorandum circulated by the U.S. House of Representatives Budget Committee to the House Republican Caucus (the “Memorandum”) containing...more
1/28/2025
/ Corporate Taxes ,
Employee Retention ,
Estate Tax ,
Foreign Earned Income ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
Municipal Bonds ,
SALT ,
Tariffs ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform