Amanda H Nussbaum

Jan 27, 2025 | proskauertaxtalks.com | Martin Hamilton |Amanda H Nussbaum |Christine Harlow |Carrie Slaton |Stuart Rosow

On January 17, 2025, multiple news outlets and other sources reported the existence of a memorandum circulated by the U.S. House of Representatives Budget

Jan 3, 2025 | jdsupra.com | Amanda H Nussbaum

On December 23, 2024, in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), the Tax Court reaffirmed its earlier ruling in Soroban Capital Partners LP v. Commissioner (161 T.C. No. 12.) that active limited partners of a state law limited partnership are not entitled to the “limited partner exception” to self-employment tax for purposes of section 1402(a)(13) of the Code. The taxpayers in Sirius Solutions LLLP v. Commissioner (Docket No. 30118-21) and Point72 Asset Management, L.P. v.

Oct 10, 2024 | natlawreview.com | Amanda H Nussbaum

On October 4, 2024, the Internal Revenue Service (the “IRS”) released Private Letter Ruling 202440007, which concluded that the lack of income and assets in the first taxable year of an entity that had elected to be treated as a real estate investment trust (“REIT”) did not cause the entity to fail to qualify as a REIT for the year. This ruling provides guidance on an issue of longstanding uncertainty.

Jun 24, 2024 | jdsupra.com | Richard Corn |Martin Hamilton |Amanda H Nussbaum

On June 17, 2024, the IRS announced the formation of a dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, which is expected to work with a new “passthrough working group” being established in the Large Business and International Division of the IRS.

Dec 28, 2023 | lexblog.com | Martine Seiden Agatston |Richard Corn |Martin Hamilton |Amanda H Nussbaum

In 2021, the Corporate Transparency Act was enacted into U.S. federal law as part of a multinational effort to rein in the use of entities to mask illegal activity, including proposed rules (effective January 1, 2024) requiring certain types of entities to file a report identifying the entity’s beneficial owners as well as the natural persons who formed the entity unless an exemption applies.