The Biden Administration Proposes Changes to the Taxation of Partnerships
On March 28, 2022, the Biden Administration proposed certain limited changes to the taxation of partnerships. In short, the Administration’s proposals would (i) prevent related partners in a...
View ArticleBlueCrest FTT Decision – Salaried Member Rules and Asset Managers
The recent decision of the First-tier Tribunal (FTT) in BlueCrest Capital Management (UK) LLP v HMRC (29 June 2022) is the first time the UK’s salaried member rules (the Rules) have been considered in...
View ArticleSummary of the Biden Administration’s Fiscal Year 2023 Green Book Tax Proposals
On March 28, 2022, the Biden Administration released the Fiscal Year 2023 Budget, and the “General Explanations of the Administration’s Fiscal Year 2023 Revenue Proposals,” which is commonly referred...
View ArticleA Summary of Inflation Reduction Act’s Main Tax Proposals
On July 27, 2022, Senator Joe Manchin (D-W.Va.) and Senate Majority Leader Chuck Schumer (D-N.Y.) released the Inflation Reduction Act of 2022 (the “IRA”). The IRA contains only two non-climate and...
View ArticleA Summary of Inflation Reduction Act’s Main Energy Tax Proposals
On August 7, the Senate passed the Inflation Reduction Act of 2022 (the “IRA”). The IRA contains a significant number of climate and energy tax proposals, many of which were previously proposed in...
View ArticleSenate Democrats Reach Agreement to Pass Inflation Reduction Act
On August 7, the Senate passed the Inflation Reduction Act of 2022 (the “IRA”). The tax provisions in the bill that was passed vary from the bill that was originally released on July 27, 2022 by...
View ArticlePresident Biden Signs Inflation Reduction Act into Law
On August 16, 2022 President Biden signed the Inflation Reduction Act of 2022 (the “IRA”) into law. The IRA includes a 15% corporate alternative minimum tax, a 1% excise tax on stock buybacks and a...
View ArticleIRS and Treasury Provide Guidance on the Excise Tax on Repurchases of...
On December 27, 2022, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) released Notice 2023-2 (the “Notice”), which provides guidance regarding the...
View ArticleRecent Legislative Proposals and IRS Guidance on the Taxation of Digital Assets
This blog post summarizes recent federal bills that have been introduced (but not yet passed), proposals by the Biden Administration, and guidance issued by the Internal Revenue Service with respect to...
View ArticleSenate Finance Committee Requests Public Comments on Digital Asset Taxation
On July 11, 2023, the Senate Finance Committee released an open letter to the Digital Asset Community asking a variety of questions in connection with possible future legislation. Public comments must...
View ArticleTax Court Holds That Active Limited Partners of State Law Limited...
Introduction Section 1402(a)(13) of the Internal Revenue Code provides that the distributive share of “limited partners, as such” from a partnership is not subject to self-employment tax.[1] Managers...
View ArticleTax Court holds that an offshore fund is engaged in a U.S. trade or business
On November 15, 2023, the U.S. Tax Court held in YA Global Investments v. Commissioner[1] that a non-U.S. private equity fund (YA Global) with a U.S. asset manager that bought equity and convertible...
View ArticleRecent Updates from the IRS and Treasury on the Superfund Chemical Tax
I. Executive Summary On February 15, 2024, the IRS and Treasury issued a supplemental notice to a prior notice from December 2022, to correct a petition requesting that the Superfund Chemical Tax apply...
View ArticleChange to non-domicile tax regime forms part of UK Spring Budget 2024
As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK...
View ArticleSummary of the Biden Administration’s Fiscal Year 2025 Green Book Tax Proposals
On March 11, 2024, the Biden Administration released the Fiscal Year 2025 Budget, and the “General Explanations of the Administration’s Fiscal Year 2025 Revenue Proposals,” which is commonly referred...
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