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Monday, August 12, 2013

McMillan: Tax Treaty Issues in Sun Capital 'Trade or Business' Ruling

Tax Analysys Logo (2013)Lori McMillan (Washburn),  Potential Treaty Issues Arise in the 'Trade or Business' Landscape, 140 Tax Notes 721 (Aug. 12, 2013):

Sun Capital [1st Cir. July 24, 2013] has added a new layer in the determination of what is a trade or business, when activity performed by members of the same group was attributed to a private equity fund. Funds can no longer be sure that merely because their income is passive, they will not be considered engaged in a trade or business.

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