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Tax Court Tax Planning U.S. Treasury

Vinson & Elkins LLP

Planning for IRS Audits in an Era of Uncertainty

Vinson & Elkins LLP on

In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions. For example, last year, the IRS...more

Morgan Lewis

Private Funds Year in Review: Key Tax Developments That Shaped the Industry in 2024

Morgan Lewis on

In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more

Eversheds Sutherland (US) LLP

Something old and something new: Final Appeals regulations maintain pre-TFA exclusions from Appeals eligibility; pilot program...

On January 14, 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (T.D. 10030) implementing section 7803(e) of the Internal Revenue Code. Section 7803(e) was...more

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