Southgate Master Fund: The Sham Partnership Doctrine Gets Messy... Or Does It?
Two weeks ago, the Fifth Circuit summarily rejected a taxpayer request for an en banc rehearing in Southgate Master Fund LLC v. United States. The appellate court had previously concluded that the...
View ArticleThe Tax Story Behind The Big Story: The Taxation Of Carried Interests In...
Editors’ note. This is the first of a new periodic series on the Tax Blawg. Mainstream press articles often implicate complex, technical tax issues. Admirably, the press attempts to simplify the tax...
View ArticleIf You're On Call, You're Out of Luck in Passive Activity Cases
Back in the era of beepers, being "on call" evoked imagery of importance. Indeed, those people required by their job to carry a beeper, along with those who did so voluntary, displayed the devices...
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