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”...more
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...more
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....more
5/27/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Corporate Taxes ,
Employee Benefits ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
New Legislation ,
Proposed Legislation ,
SALT ,
Tax Credits ,
Tax Deductions ,
Tax Rates ,
Tax Reform
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...more
On May 12, 2025, the House Ways and Committee released an updated text of draft tax legislation (the “House Draft Bill”)...more
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...more
4/29/2025
/ Final Rules ,
IRS ,
Partnerships ,
Penalties ,
Proposed Regulation ,
Regulatory Agenda ,
Related Parties ,
Reporting Requirements ,
Revenue Rulings ,
Tax Policy ,
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...more
3/5/2025
/ Compliance ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Liquidation ,
Partnerships ,
Penalties ,
Regulatory Agenda ,
REIT ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
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...more
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...more
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...more
1/28/2025
/ Corporate Taxes ,
Employee Retention ,
Estate Tax ,
Foreign Earned Income ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
Municipal Bonds ,
SALT ,
Tariffs ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform