On May 28, 2025, the U.S. Tax Court issued its decision in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) (“Soroban”), holding that “limited partners” of a management company organized as a Delaware limited...more
The year just past, 2023, brought three significant U.S. Tax Court decisions that raise important ongoing tax considerations for private funds. These cases addressed: whether a non-U.S. credit fund had income effectively...more