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