In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more
1/31/2025
/ Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Private Equity Funds ,
Private Funds ,
Regulatory Requirements ,
Tax Court ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Reform ,
U.S. Treasury
The Internal Revenue Service (IRS) issued notification letters earlier this year to victims of a former IRS contractor, Charles Littlejohn, who illegally accessed and stole the tax return information of thousands of companies...more
As family offices continue to adapt to economic, financial, and technological changes, several ongoing developments are giving family offices plenty consider heading into 2025, including gift and estate tax exemptions, which...more
As required by law, the Internal Revenue Service (IRS) has begun issuing notification letters to victims of a former IRS contractor who illegally accessed and stole the tax return information of thousands of companies and...more
Sports industry partnerships are now on notice that the Internal Revenue Service (IRS) is initiating specialized, issue-based BBA partnership examinations focusing on their income and deductions....more
Private equity, hedge fund, and other investment fund sponsors should be aware of the recent development in the Internal Revenue Service’s (IRS’s) audit campaign with respect to potential liability for Self-Employment...more
Private equity, hedge fund, and other investment fund sponsors should be aware that there continue to be significant developments in the Internal Revenue Service's (IRS’s) audit campaign with respect to the potential...more
A recent challenge to the constitutionality of the federal excise tax on domestic crude oil exported from the United States proved successful in the US Court of Appeals for the Fifth Circuit. While the US Department of...more
The Internal Revenue Service on July 6 published answers to frequently asked questions regarding the taxability of payments received by eligible healthcare providers from the Public Health and Social Services Emergency...more
As part of its ongoing efforts to provide guidance on the federal income tax consequences of various Coronavirus Aid, Relief, and Economic Security (CARES) Act provisions, the IRS issued Notice 2020-32 addressing the...more
In continued efforts to help taxpayers address the challenges brought on by the coronavirus (COVID-19) pandemic, the Internal Revenue Service announced further relief on April 9, including automatically extending deadlines...more
Overwhelmingly passed by both houses of the US Congress this week and signed into law by President Donald Trump on March 27, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) provides a $2 trillion economic...more
4/1/2020
/ Business Interruption ,
Business Taxes ,
CARES Act ,
Coronavirus/COVID-19 ,
Federal Loans ,
Financial Stimulus ,
IRS ,
Relief Measures ,
SBA Lending Programs ,
Small Business ,
Tax Relief
The Internal Revenue Service on March 24 published a first set of answers to frequently asked questions regarding the federal income tax return filing and payment relief provided in Notice 2020-18. This LawFlash discusses the...more
The day after US Secretary of the Treasury Steven Mnuchin’s announcement on March 17, the Internal Revenue Service issued helpful guidance (Notice 2020-17) on the coronavirus (COVID-19) crisis. Importantly, the IRS is...more
Two days after extending by 90 days the deadline for payment of certain federal income taxes, on March 20, US Secretary of the Treasury Steven Mnuchin announced that the Internal Revenue Service will also extend the deadline...more
3/22/2020
/ Coronavirus/COVID-19 ,
Corporate Taxes ,
Federal Taxes ,
Filing Deadlines ,
Filing Requirements ,
Income Taxes ,
IRS ,
Relief Measures ,
Required Forms ,
Secretary of the Treasury ,
Tax Extensions ,
Tax Returns ,
Time Extensions ,
U.S. Treasury
In light of a recent pilot program encouraging the inclusion of Exam members in Appeals conferences, as well as an indication that Appeals conferences will return to being face-to-face meetings, taxpayers may want to consider...more
Victims of Hurricane Harvey in some designated areas now have until January 31, 2018 to file certain federal tax returns and make payments....more
All partnerships will be audited at the entity level unless they have 100 or fewer partners AND no partnerships as direct partners.
The two-year budget plan passed by Congress on October 30, 2015, and expected to be...more
11/3/2015
/ Audits ,
Barack Obama ,
Federal Budget ,
Federal Taxes ,
Indemnification ,
IRS ,
New Legislation ,
Participation Agreements ,
Partnership Agreements ,
Partnerships ,
Repeal ,
Tax Deductions ,
Tax Liability ,
TEFRA ,
U.S. Treasury