Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more
2/24/2025
/ Foreign Corporations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Repeal ,
Tax Exemptions ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
U.S. Commerce Department
Memorandum to our Investment Management Clients and Friends -
The United States Tax Court recently issued a ruling (the “Ruling”) pertaining to the possible exclusion of a limited partner’s distributive share of income...more
12/5/2023
/ Audits ,
Cross Motions ,
Fund Managers ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Management ,
IRS ,
Limited Partnerships ,
Motion for Summary Judgment ,
Self-Employment Tax ,
Tax Court