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
On December 2, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations (the “Final Regulations”) on section 752 regarding the allocation of partnership…
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/ Business Organizations, Commercial Law & Contracts, Taxation
On January 17, 2025, news sources reported that Republican members of Congress circulated a detailed list of legislative policy options, including tax proposals. This blog post summarizes some of the tax proposals and…
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/ Business Organizations, Elections & Politics, Taxation
The Court of Appeal has remitted the case of BlueCrest Capital Management (UK) LLP (BlueCrest) v HMRC back to the First-tier Tribunal (FTT) regarding the application of the UK’s salaried members rules (the Rules) to certain…
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/ Business Organizations, Finance & Banking, Taxation
On January 17, 2025, multiple news outlets and other sources reported the existence of a memorandum circulated by the U.S. House of Representatives Budget Committee to the House Republican Caucus (the “Memorandum”) containing an…
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/ Business Organizations, International Law & Trade, Taxation
On January 20, 2025, the White House issued a memorandum (the “Memorandum”), announcing that the “Organization for Economic Co-operation and Development (OECD) Global Tax Deal” (the “Global Tax Deal”) has “no force or effect in…
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/ Administrative Law, International Law & Trade, Taxation
On December 23, 2024, in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), the Tax Court reaffirmed its earlier ruling in Soroban Capital Partners LP v. Commissioner (161 T.C. No. 12.) that active limited…
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/ Business Organizations, Civil Procedure, Taxation
With clear Republican victories in the White House and the Senate, and a very slim majority for either side in the House of Representatives, we can expect tax legislation in the coming year. It is expected that the President…
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/ Business Organizations, Elections & Politics, Taxation
On Wednesday 30 October 2024, the UK government announced changes to the UK taxation of carried interest as part of the 2024 Autumn Budget. Changes were expected following statements made by the Labour Party in the run up to…
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/ Business Organizations, Finance & Banking, Taxation
