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The Tax Lawyer | Spring 2021

Volume 74, Issue 3


When Does a BBA Partnership Terminate?

Andrew Lawson

The death of a tax partnership has recently taken on increased importance.Under the centralized partnership audit regime enacted as part of the BipartisanBudget Act of 2015 (the BBA), whether a partn…

Jun 06, 2021 67 min read

The Tax Guide to Offshore Lending

David S. Miller

The Article explains the various structures that permit offshore funds with U.S. managers to originate loans without the fund or its investors being subject to any meaningful amount of U.S. tax. ...

Jun 06, 2021 111 min read