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On April 16, 2024, Ameek Ashok Ponda, with assistance from Paul Decker, Sarah Wellings and Connie Lee, submitted a comment letter to the Internal Revenue Service (IRS) regarding his...
A recent U.S. Tax Court decision provides clarity to what the Internal Revenue Service ("IRS") considers a limited partner for purposes of the ‘limited partner exception...
The Internal Revenue Service (IRS) recently issued a nonbinding Generic Legal Advice Memorandum (GLAM) that provides advice on Internal Revenue Code Section 482 and so-called implicit...
As Congress heads into 2024 and President Biden starts the last year of his term, a host of tax issues remain unaddressed, including a much-anticipated expiring tax provisions package,...