Sarah-Jane Morin

May 6, 2024 | jdsupra.com | Kendall J. Keshtkar |Richard C. LaFalce |Sarah-Jane Morin

On April 24, the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding Section 897. In December 2022, the IRS issued proposed regulations under Sections 897 (the Proposed Regulations) and 892 of the Internal Revenue Code of 1986, as amended (the Code), providing guidance related to “domestically controlled” qualified investment entities and exemptions for foreign government investors, respectively.

May 3, 2024 | morganlewis.com | Richard C. LaFalce |Sarah-Jane Morin |Daniel Nelson |Kendall J. Keshtkar

On April 24, the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding Section 897. In December 2022, the IRS issued proposed regulations under Sections 897 (the Proposed Regulations) and 892 of the Internal Revenue Code of 1986, as amended (the Code), providing guidance related to “domestically controlled” qualified investment entities and exemptions for foreign government investors, respectively.

Sep 6, 2023 | morganlewis.com | Robert Mailer |Sarah-Jane Morin |Susan Cohen |Eliska Macnerova |Christopher Lloyd |Aaron Nemeti

LONDON, September 6, 2023: Morgan Lewis advised Air Street Capital on the launch of Air Street Fund II, an approximately $121 million fund that focuses solely on backing artificial intelligence (AI)–first companies. Morgan Lewis previously advised on the establishment of Air Street Capital’s first fund. Air Street Capital is a venture capital firm investing in AI-first technology and life science companies across North America and Europe.

May 25, 2023 | lexology.com | Sarah-Jane Morin |Richard Zarin |Daniel Carmody |Daniel Nelson |Scott Lee |Kendall J. Keshtkar

A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a partnership profits interest in exchange for services can support non-taxable treatment at grant. WHAT IS A PROFITS INTEREST? Under IRS Revenue Procedure 93-27 [1] (Rev.

May 25, 2023 | morganlewis.com | Sarah-Jane Morin |Richard Zarin |Daniel Carmody |Daniel Nelson

A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a partnership profits interest in exchange for services can support non-taxable treatment at grant. WHAT IS A PROFITS INTEREST? Under IRS Revenue Procedure 93-27 [1] (Rev.