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
The United States and Switzerland jointly announced the conversion of the intergovernmental agreement (“IGA”) from a “Model 2” to “Model 1” agreement. The new IGA will come into effect January 1, 2027, allowing time for...more
Memorandum to our Investment Management Clients and Friends -
The United States Tax Court recently issued a ruling (the “Ruling”) pertaining to the possible exclusion of a limited partner’s distributive share of income...more
12/5/2023
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