On May 22, 2025, the House of Representatives passed by a one-vote margin the “One Big Beautiful Bill Act” (the “House Bill”), which has now moved to the Senate for consideration. This Memorandum discusses the House Bill’s...more
6/9/2025
/ Foreign Corporations ,
Foreign Investment ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Investors ,
IRS ,
New Regulations ,
Proposed Legislation ,
Taxation ,
U.S. Treasury
Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more
2/24/2025
/ Foreign Corporations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Repeal ,
Tax Exemptions ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
U.S. Commerce Department
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
Last week, the Internal Revenue Service (“IRS”) proposed regulations (the “Proposed Regulations”) to treat certain basket contracts as listed transactions. Basket contracts were previously identified as transactions of...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
/ Audits ,
Cross Motions ,
Fund Managers ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Management ,
IRS ,
Limited Partnerships ,
Motion for Summary Judgment ,
Self-Employment Tax ,
Tax Court
This Memorandum highlights several important U.S. federal income tax developments in the summer of 2022, including: (i) the Supreme Court agreeing to hear an FBAR penalty case, (ii) the Internal Revenue Service (“IRS”)...more