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For Tax Purposes, Are Limited Partners Really Limited Partners?

In Soroban Capital Partners v. Commissioner, the United States Tax Court determined that entities formed as state law limited partnerships did not necessarily mean that the limited partnerships’ limited partners were limited...more

IRS Announces Audits of Business Jet Usage as Part of Larger Effort to Target High-Income Taxpayers

On February 21, 2024, the IRS announced plans to begin audits on aircraft that may be used for both business and personal purposes. This push is a part of the IRS’s broader focus on improving tax compliance in high-income...more

Digital Assets Reporting Requirements Under Section 6050I

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

IRS Announces Voluntary Disclosure Program for Employee Retention Credit (ERC)

By: Matthew E. Foreman, Esq., LL.M. and Samuel J. Brady On December 21, 2023, the IRS announced a new Voluntary Disclosure Program (the “Program”), allowing employers (both businesses and not-for-profits) who received the...more

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