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Taxpayer Victory in US Tax Court Highlights Need for Properly Structuring Partnership Profits Interests

A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a...more

COVID-19: Opportunistic and Dislocation Funds Pursuing Credit Strategies

The widespread economic disruption precipitated by the coronavirus (COVID-19) global pandemic and oil price volatility has caused debt portfolios to come under scrutiny and fund sponsors and investors to consider...more

Tax Reform Bill Proposes to Eliminate UBTI Exemption for Government Plans

House bill, if enacted, will alter tax analysis with respect to fund investments. On November 2, House Republicans released their draft tax reform bill. Of particular interest to government pension plans is a provision...more

Grecian Magnesite Mining: Impact on Investments by Non-US Investors in US Funds

US Tax Court decision may facilitate tax-efficient investment structures for non-US investors investing in US operating partnerships, directly or through investment funds....more

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