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”…
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/ Business Organizations, Finance & Banking, Taxation
On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (H.R. 1, hereafter the “Revised House Bill”). The Revised House Draft Bill contains certain changes to the original bill that was released on…
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/ Education Law, Nonprofit Law, Taxation
June 2025 – The UK Government has published its response to the consultation on its proposal to change the tax treatment of carried interest, confirming the expected final shape of the new regime which will take effect from…
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/ International Law & Trade, Taxation
The One Big Beautiful Bill Act (the “OBBBA“), passed by the U.S. House of Representatives (the “House“) on May 22, 2025, is a comprehensive legislative package that seeks to implement sweeping reforms in tax policy, immigration,…
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/ Administrative Law, Finance & Banking, Securities Law, Taxation
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 in…
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/ Commercial Law & Contracts, Finance & Banking, Taxation
On May 20, 2025, California’s Franchise Tax Board (“FTB”) released changes to the proposed regulations (“Draft Regulations”) that would amend the rules regarding market-based sourcing for sales other than sales of tangible…
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/ Administrative Law, Franchise Law, Taxation
On Thursday May 22, the House of Representatives passed the One Big Beautiful Bill Act (H.R. 1, hereafter the “Bill”). The Bill will now be considered by the U.S. Senate…
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/ Business Organizations, Nonprofit Law, Taxation
On May 22, 2025, the House of Representatives passed the draft tax legislation (the “Revised House Draft Bill”). The Revised House Draft Bill contains certain changes to the original bill that was released on May 12, 2025 by…
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/ Art, Entertainment, & Sports Law, Taxation
On May 18, 2025, the House Budget Committee approved the legislation entitled, “The One, Big, Beautiful Bill” (the “House Bill”). The bill is expected to be revised by the House Rules Committee before being sent to the House…
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/ Business Organizations, Finance & Banking, Taxation
On May 12, 2025, the House Ways and Committee released an updated text of draft tax legislation (the “House Draft Bill”)..…
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/ Education Law, Nonprofit Law, Taxation
On May 12, 2025, the House Ways and Means Committee released an updated text of draft tax legislation (the “House Draft Bill”)..…
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/ Art, Entertainment, & Sports Law, Nonprofit Law, Taxation
On May 12, 2025, House Republicans unveiled a comprehensive 389-page package of tax provisions, setting the stage for a significant tax bill to be debated in the coming weeks. Dubbed the “One Big Beautiful Bill,” this proposal…
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/ Taxation
On April 17, 2025, the U.S. Internal Revenue Service (the “IRS”) issued Notice 2025-23 (the “Notice”), announcing its intention to withdraw the recently released final regulations final regulationsthat classify certain…
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/ Finance & Banking, Taxation
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…
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/ Business Organizations, Real Estate - Commercial, Taxation
On January 30, 2025, Mike Crapo (R-ID), the Chairman of the Senate Finance Committee, and Senator Ron Wyden (D-OR), the Ranking Member of the Senate Finance Committee released a discussion draft of the “Taxpayer Assistance and…
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/ Alternative Dispute Resolution (ADR), Civil Procedure, Taxation
