On August 19, the IRS released Notice 2025-45 (the “Notice”), announcing its plan to reduce barriers to certain redomiciliations. In particular, the IRS reduced barriers to redomiciliations by foreign publicly traded...more
8/26/2025
/ Cross-Border Transactions ,
Distribution Rules ,
Domicile ,
FIRPTA ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Publicly-Traded Companies ,
Reorganizations ,
Stocks ,
Tax Planning ,
Tax Relief
The latest chapter in the IRS attack on the use of a self-employment tax exception by fund managers came in the form of another Tax Court opinion last month in Soroban Capital Partners LP v. Commissioner (“Soroban II”) The...more
On May 12, 2025, the House Ways & Means Committee released legislative text for a new code section 899 designed to impose retaliatory tax measures against unfair foreign taxes, including digital services taxes and the...more