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ABCs of Fund Formation

USA - February 14 2017 So you want to form a fund - everybody's doing it, right? More and more entrepreneurs are exploring whether to form a fund to fulfill their…

Michael R. Manley, Nikhil N. Matani.

Blocker Corporation Meets Accumulated Earnings Tax—Really?

USA - March 9 2017 In Chief Counsel Advice 201653017, released on December 30, 2016 (the CCA), the National Office of the Office of Chief Counsel, the Internal Revenue…

Rise of the Disregarded Entities

USA - January 9 2017 A new U.S. tax regulation is bringing back to life entities the fund community has taken for granted as dead for U.S. tax purposes. It requires U.S…

Disregarded Entity Partners Raise Gummy-Bears for Tax Audit Risk Management

USA - July 7 2017 In June, the U.S. Court of Appeals for the Ninth Circuit held that a single-member LLC (disregarded entity) holding an interest in an LLC (treated as…

Chaim Gordon.

Effectively Connected Income and Penny Warrants

USA - June 21 2017 There is a case currently proceeding in the U.S. Tax Court (TELOS CLO 2006-1, Ltd. v. Commissioner, T.C., No. 6786-17, petitions filed 3/22/17) that…

Nicholas A. Jacobus.