A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a...more
Private equity, hedge fund, and other investment fund sponsors should be aware that there continue to be significant developments in the Internal Revenue Service's (IRS’s) audit campaign with respect to the potential...more
The US Internal Revenue Service (IRS) issued proposed regulations on May 7 that would expand tax withholding and reporting requirements in certain sales or exchanges of interests in partnerships engaged in one or more US...more