By: Amanda Wilson The budget bill introduced yesterday includes a proposal to revamp/streamline how partnerships are audited. Specifically, it would repeal the much maligned TEFRA (1982 Tax Equity and Fiscal Responsibility Act) rules. The overall...

By: Amanda Wilson Yesterday, Senators Franken, Warren, Baldwin and Whitehouse sent Treasury Secretary Lew a letter regarding management fee waiver arrangements. What is a management fee waiver arrangement? It is where a fund manager waives its...

By: Amanda Wilson As my prior blog posts have discussed (see most recent here), we are seeing repeated efforts to disallow favorable tax treatment of carried interests in partnership. Earlier this week, President Obama once again called for Congress...

By: Amanda Wilson The Obama administration and top lawmakers are in discussions regarding a potential overhaul of how the United States taxes U.S. multinational corporations. Topics under consideration include eliminating the U.S. approach of taxing...