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Chipping Away At The Investor Exception? Implications Of The YA Global Case For Foreign Investors In US Private Funds - Income Tax

On November 15, 2023, the United States Tax Court held in YA Global v. Commissioner that a private fund specializing in Private Investment In Public.

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YA Global, the Existence of a U S Trade or Business, and the Search for Greater Clarity | Alston & Bird

Our Federal & International Tax Group examines a long-awaited Tax Court ruling that helps clarify when a non-U.S. company engages in a “U.S. trade or business.”

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Tax Court Holds That It Has Jurisdiction Over Case Due To IRS Error

Generally, taxpayers who receive a notice of deficiency have 90 days after the notice’s issuance date to file a petition with the Tax Court.

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IRS Audit Attorney - Top 7 To Consider For 2024

IRS Audit Attorney - Top 7 To Consider For 2024
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A Decision in US Tax Court Affects Limited Partners and SECA | Allen Barron, Inc

A recent decision in the US Tax Court affects limited partners and SECA – the Self Employed Contributions Act. In this case, Soroban Capital Partners LP (a hedge fund management.

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