In the latest self-employment tax ruling, the Fifth Circuit Court of Appeals issued a ruling in Sirius Solutions, L.L.L.P. v. Commissioner (the “Ruling”) that will ultimately permit state-law limited partners to exclude their...more
On December 12, the Treasury Department issued Proposed Treasury Regulations which, for the first time, appear to provide a potential window into the Internal Revenue Service’s view as to when an investment in debt...more
On December 12, the Treasury Department issued final Treasury Regulations (the “Final Regulations”) and proposed Treasury Regulations (the “Proposed Regulations”) that address various issues under Section 892 of the Internal...more
The One Big Beautiful Bill Act (the “OBBBA”), which was signed into law on July 4, 2025, contained a big, beautiful surprise for qualified small business stock (“QSBS”) investors. Individual investors, private equity funds...more
8/25/2025
/ Capital Gains ,
Capital Gains Tax ,
Investment Funds ,
New Legislation ,
New Rules ,
One Big Beautiful Bill Act ,
Private Equity ,
Qualified Small Business Stock ,
Small Business ,
Tax Incentives ,
Tax Planning ,
Venture Capital
This Memorandum continues our analysis of the current U.S. federal tax reform process. Today, the House of Representative passed the Senate’s version of the One Big, Beautiful Bill (the “Senate Tax Bill”). The Senate Tax Bill...more
On May 22, 2025, the House of Representatives passed by a one-vote margin the “One Big Beautiful Bill Act” (the “House Bill”), which has now moved to the Senate for consideration. This Memorandum discusses the House Bill’s...more
6/9/2025
/ Foreign Corporations ,
Foreign Investment ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Investors ,
IRS ,
New Regulations ,
Proposed Legislation ,
Taxation ,
U.S. Treasury
Tax Court Delivers Coal to Another Limited Partnership Management Company -
On December 23, 2024, the United States Tax Court published an opinion1 (the “Opinion”), holding that limited partners that actively participated...more
Federal income tax law offers tax advantages to taxpayers that save money in specially designated accounts earmarked for future educational expenses (“529 Accounts”). In addition, federal income tax law also incentivizes...more