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
On October 17, 2023, the Internal Revenue Service (IRS) updated the electronic signature guidance in its Internal Revenue Manual (IRM) to reflect the electronic signature relief that the IRS provided to taxpayers during the...more
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
On Aug. 6, New York Attorney General Letitia James and D.C. Attorney General Karl Racine brought blockbuster lawsuits against the National Rifle Association and the National Rifle Association Foundation, alleging that these...more
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
A new “centralized partnership audit regime” is now in effect for partnerships, including limited liability companies (LLCs) that are treated as partnerships for tax purposes (which we refer to collectively as...more