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One Big Beautiful Bill Act – Tax Considerations for Investment Funds

On July 4, 2025, President Donald Trump signed into law extensive tax legislation as part of the One Big Beautiful Bill Act (OBBBA) that will impact the investment fund industry.  Perhaps one of the most important aspects...more

Trump Administration Passes the One Big Beautiful Bill Act

On July 4, 2025, President Trump signed H.R. 1—referred to as the One Big Beautiful Bill Act (OBBBA). The OBBBA extends and makes permanent certain provisions in the 2017 Tax Cuts and Jobs Act (TCJA) that were set to expire...more

Tax Court Reaffirms Soroban Holding that “Active” Limited Partners are Subject to Self-Employment Tax

On December 23, 2024, the Tax Court ruled in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), that limited partners that actively participated in the activities of a fund manager formed as a state law...more

Selling Your Company With Cash in the Bank? U.S. Federal Income Tax Considerations for Structuring Pre-Closing Payments To Target...

Are you preparing to sell your company with cash in the bank? A common construct for valuation is on a cash-free and debt-free basis, such that seller can recover the cash in a pre-closing purchase price adjustment. A...more

U.S. Tax Court Ruling Exempts Gain on Foreign Partner's Sale of a Partnership Interest

On July 13, 2017, the U.S. Tax Court issued a decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3, which could have a significant impact on how non-U.S. investors invest in U.S....more

Partnership Tax Audit Reform and Private Funds

The Bipartisan Budget Act of 2015 that was signed into law on November 2, 2015, made extensive changes to the rules that apply to partnership audits and the mechanics for collecting taxes resulting from an audit. These...more

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