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Restructuring Tax Exempt Entities

Ice Miller

Uncertainty at the IRS: Why Qualified Pension Plans Should Self-Audit

Ice Miller on

The Internal Revenue Service (IRS) began terminations of employees on February 20, 2025, with initial news reports of layoffs set to 6,000 terminations and a stated intent to downsize its workforce by upwards of 50 percent as...more

Proskauer Rose LLP

Proskauer's Hedge Start: Key Structuring Issues

Proskauer Rose LLP on

A key initial decision for a manager launching a new hedge fund is to decide between: A “master-feeder” fund structure: In a typical “master-feeder” structure, an onshore “feeder” fund and an offshore “feeder” fund both...more

Morgan Lewis

Tax-Exempt Organization Restructurings Made Easier

Morgan Lewis on

Many tax-exempt organizations can now change their state of organization and retain their current tax exemption. Revenue Procedure 2018-15 provides that, in most circumstances, tax-exempt organizations no longer need to...more

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