On May 28th, the U.S. Tax Court issued a decision in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) holding that all of the income allocable to the partnership’s limited partners (not just the amount...more
6/3/2025
/ Appeals ,
Fund Managers ,
Income Taxes ,
Investment Funds ,
IRS ,
Limited Partnerships ,
Partnerships ,
Private Equity Funds ,
Self-Employment Tax ,
Tax Court ,
Tax Liability
In the event of an M&A transaction, many stockholders plan to take advantage of the exclusion from federal taxable income of gain realized from the sale or exchange of “qualified small business stock” (QSB stock). Section...more
6/16/2023
/ Acquisitions ,
C-Corporation ,
Capital Gains ,
Federal Taxes ,
Gain Exclusion ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Mergers ,
Qualified Small Business Stock ,
Shareholders ,
Small Business ,
State Taxes ,
Tax Planning
In our prior nonprofit alert, we reported that the Internal Revenue Service (the “IRS”) had not extended most federal tax payment and filing deadlines for exempt organizations. The IRS notices issued up to that point (Notice...more
Federal tax law changes enacted with the Tax Cuts and Jobs Act of 2017 may require tax-exempt organizations to reevaluate their compensation practices, particularly with respect to employee severance. Section 4960 of the...more