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
On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385. The final and temporary regulations recharacterize certain debt instruments as equity for...more
10/27/2016
/ Asset Stripping ,
Bifurcation ,
Debt ,
Debt Instruments ,
Disregarded Entities ,
Equity ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Publicly-Traded Companies ,
Section 385 ,
Securities ,
Stocks ,
U.S. Treasury