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Foley & Lardner LLP

YA Global Heads to Appeals Court Over Tax Court Ruling on Offshore Fund’s U.S. Activities

Foley & Lardner LLP on

Share on LinkedIn Share on Twitter Print Share by Email Share Back to top Last month, YA Global Investments, LP (the “Fund”) filed a notice of appeal to the U.S. Court of Appeals for the Third Circuit, seeking review of the...more

Alston & Bird

YA Global, the Existence of a U.S. Trade or Business, and the Search for Greater Clarity

Alston & Bird on

Our Federal & International Tax Group examines a long-awaited Tax Court ruling that helps clarify when a non-U.S. company engages in a “U.S. trade or business.”...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Rolls Out Long-Planned Strategy Targeting Large Partnerships and High-Wealth Individual Taxpayers

Skadden, Arps, Slate, Meagher & Flom LLP on

On September 8, 2023, Internal Revenue Service (IRS) Commissioner Danny Werfel announced the rollout of a coordinated enforcement strategy that will involve audits of returns filed by 75 of the largest partnerships operating...more

Akin Gump Strauss Hauer & Feld LLP

CFTC and NFA Year End Regulatory Updates

Akin Gump Strauss Hauer & Feld LLP on

• Effective January 1, 2020, clarifying amendments to rules regarding communications with the public and use of promotional material will go into effect. • Effective February 1, 2020, CTA will be subject to new limitations...more

Ballard Spahr LLP

DOJ Secures First Ever Conviction for Violating FATCA

Ballard Spahr LLP on

The Department of Justice (“DOJ”) has secured its first conviction ever under the Foreign Account Tax Compliance Act, or FATCA, through the guilty plea of Adrian Baron, a former executive of Loyal Bank Ltd., a bank with...more

Gerald Nowotny - Law Office of Gerald R....

Looking Over the Edge of the Cliff– The Use of Pooled Income Funds for the Repatriation of Offshore Carried Interest

Gerald Nowotny - Law Office of Gerald R.... on

The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more

K&L Gates LLP

Superannuation Funds - Enhanced Investment Management Governance

K&L Gates LLP on

The Australian Government has been rolling out a series of significant regulatory reforms of the superannuation industry, many of which will commence in 2013. These reforms are fundamentally designed to enhance the prudential...more

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