Monday, August 12, 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.
- New York Times DealBook: Sun Capital Court Ruling Threatens Structure of Private Equity, by Vic Fleischer (San Diego)
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