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Articles by Alison Chen
Second Circuit Affirms IRS Position, Resulting in Setback for New York Resident Limited Partners on Self-Employment Tax
Key Points The Court of Appeals for the Second Circuit affirmed the Tax Court holding that a partner must lack managerial control over a partnership before it can qualify for the “limited partner exception” from self-employment taxes. New York and Connecticut based asset managers who previously have claimed the exemption may no longer be able to take the same reporting positions going forward.
Fifth Circuit Overrules Tax Court, Providing Major Victory for Limited Partners on Self-Employment Tax | JD Supra
In a significant decision for the investment funds industry, the U.S. Court of Appeals for the Fifth Circuit has officially rejected the Internal Revenue Service (IRS)’s “passive investor” test for the limited partner self-employment tax exception. On January 16, 2026, the court ruled in Sirius Solutions LLLP v. Commissioner that any limited partner in a state-law limited partnership who enjoys limited liability qualifies for the exclusion of their profit shares from self-employment (SECA) taxes.
New Section 892 Regulations: Action Points for Private Fund Sponsors and Non-U.S. Pension Plan & Sovereign Investors | JD Supra
The Department of the Treasury has finalized highly anticipated Treasury regulations (the Final Regulations) that provide certain non-U.S. sovereign and pension plan investors who rely on the U.S. sovereign exemption under Section 892 of the U.S. Internal Revenue Code (Sovereign Investors) opportunities to greatly simplify the structuring of their U.S. and global investments.
Evidence for balancing selection on loci associated with host use in the genome of a generalist plant parasite
Abstract Most research on host-parasite interactions has focused on tightly coevolved species pairs, yet many parasites are generalists that infect a wide range of host taxa. Generalist parasites are subject to highly variable selection pressures across different hosts and the footprints that this heterogeneous selection leaves in the genomes of generalists have been largely unexplored.
Trends in Oil & Gas 2023 and the Year Ahead
Find out more about Lexology or get in touch by visiting our About page. Register To view this article you need a PDF viewer such as Adobe Reader. If you can't read this PDF, you can view its text here. Go back to the PDF .
Clean Energy Tax Credit Transferability Guidance Issued
On June 14, 2023, the Internal Revenue Service and the Treasury Department issued (among other guidance) an expansive set of proposed regulations explaining how taxpayers can monetize 11 green energy tax credits through transferability (the ability to transfer or sell the credit to an unrelated taxpayer).
Clean Energy Tax Credit Transferability Guidance Issued | JD Supra
June 23, 2023 Shariff N. Barakat, Alison Chen, Jeff Cohen, Amy Elliott, Ike Emehelu, Matthew Kapinos, Daniel Lynch, Brandon Morris, Aaron D.
Treasury Updates Guidance Issued Last Week on 'Energy Community' Tax Credit Adders | JD Supra
Summary On April 4, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) released guidance on the “energy community” tax credit adders (EC Adders) that were added under the Inflation Reduction Act (IRA). The guidance is in the form of IRS Notice 2023-29 (Notice).
Treasury Updates Guidance Issued Last Week on 'Energy Community' Tax Credit Adders
Summary On April 4, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) released guidance on the “energy community” tax credit adders (EC Adders) that were added under the Inflation Reduction Act (IRA). The guidance is in the form of IRS Notice 2023-29 (Notice).
Nevertheless, Chinese Civil Society Persisted
Crickets Unwilling to Lie Flat In April 2021, less than two months after Chinese leader Xi Jinping declared the country free of extreme poverty, a Chinese Internet user with the handle “Kind Traveler” posted on an online forum: “I have not had a formal job for two years. Just having fun. I don’t think there’s anything wrong with this. . .
China’s Record Urban Youth Unemployment
Qin Chen is a writer and editor based in Shanghai. She focuses on China’s tech industry and related policies and is an observer of Chinese society. In her previous life, she was a Beijing-based... Alison Sile Chen is a Ph.D. student in the Political Science department at the University of California, San Diego, studying authoritarian surveillance. Before coming to the U.S. to pursue an...
Is Hong Kong about to Get Its Own Foreign NGO Law in the Name of ‘National Security’?
On May 28, China’s National People’s Congress (NPC) issued a much-anticipated Decision on preservation of national security in Hong Kong. The key paragraph in the short document authorized the NPC’s Standing Committee to “draft laws related to . . .
Energy Companies Contemplating Repurchase Of Discounted Debt Should Carefully Analyze Corporate, Securities Law And Tax Considerations - Energy and Natural Resources - United States
To print this article, all you need is to be registered or login on Mondaq.com. As the economic turbulence associated with the downturn in commodity prices and the outbreak of COVID-19 continues, many energy companies may find their debt trading at significant discounts. For companies trying to manage liability and liquidity, this presents an opportunity to selectively repurchase debt and de-lever at prices well below par.
Energy Companies Contemplating Repurchase of Discounted Debt Should Carefully Analyze Corporate, Securities Law and Tax Considerations | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Event Recap: What to Make of India's Election Results?
At the close of the Indian election last month, Narendra Modi, the incumbent Prime Minister, won re-election with a significant margin. On May 28th, Michael Kugelman, Deputy Director of the Asia Program, hosted a Ground Truth Briefing examining the implication of the Indian election.
Should I Be Gluten-Free?
GLUTEN-FREE (GF) IS A CATCHY FAD that has become more popular over the last few years. You've probably seen many different gluten-free options at restaurants, grocery stores and bakeries. But is it really healthier to eat gluten-free? Or is that all it is...
6 Exercises To Make Sure You Keep Your New Year's Resolutions
How are your New Year's Resolutions going?
How To Have A Healthy, Safe (And Green) Halloween
Orange and Black have always been the designated colours of Halloween.
Here's How To Eat Healthy While Saving Time And Money
There's nothing quite like a home cooked meal, but be honest, how many of you have the time to spend on preparing healthy meals, with quality ingredients, on a daily basis?By the time many of us get home from a busy day at work, or start to think about what to put on the dinner table after a hectic day with the kids, all we want to do is reach into the freezer to pull out whatever pre-packaged, processed frozen dinner we have, or hit the speed dial to our favorite pizza joint.While take-out...
The Real Reasons Why You're Having Stomach Problems
DO YOU EVER FEEL BLOATED, tired, gassy, heavy or sick after eating? Perhaps a better question to ask is do you know WHY you sometimes feel this way?When I was a kid, my family would joke about calling "dibs" on the washroom in the house after a big meal out. To me, this was normal.
8 Healthy Extras You Can Do Every Day
GETTING INTO SHAPE and staying healthy has suddenly taken an elitist position. Only the well-educated, financially stable and motivated individuals can make it.
5 Easy Ways To Stay Healthy While Travelling
I LOVE to travel; seeing new places, making new friends, and going on adventures. I love living a life where I'm excited to see what is just around the corner... or more accurately, around the globe!You know what else I love?
13 Cooking Methods And How They Affect Your Health
So, what's for dinner? From meatloaf to pasta and salad to stir-fry, for many the options are limitless. All you need is a good cookbook, some ingredients on hand, and a little know-how.When it comes to our health FOODS AND BEVERAGES are the most important things we put into our bodies.
15 Ways Men Can Acheive a Healthy State of Mind -
Creativity and hobbies Meditation Gratitude Human touch and contact Perception and empathy Mindfulness Positive self talk, while avoiding gossip and comparisons Smiling and laughter Electronic impact Physical activity Intention and optimism Wholesome entertainment – Music, books, movies, cognitive games Community and social support Completing tasks Food for mood 1.
Look Out For These 7 Toxins You Consume Every Day
Toxins are all around us. Whether it's the car fumes you inhale, the frozen dinner you eat, or the negative thoughts you have at work, toxins are everywhere.Note: to some degree, everything can be toxic in the right amounts, even oxygen and water.
What 7 Shades Of Poo Say About Your Health
We all do it, don't deny it. We all look at our poo. Whether it's with a casual glance or a long, hard stare, we all stop for a moment to witness what our body has produced. And for the record, I'm glad you do! As a naturopathic doctor some of the most important, albeit sometimes awkward, questions I ask are about your bowel movements, a.k.a. your poo.
8 Tips To Be Healthier With Gratitude
What are you grateful for?No, I'm not trying to bring to mind your most recent family Thanksgiving dinner, the one where you dodged Uncle Bob and Aunt Rita's inquisition as to your school/ work/ relationship status! Rather, I'm trying to get you to stop, think, and reflect on your perception of life, and an incredibly important part of our good health: Gratitude.While many of us may be thankful for that once-a-year holiday, being grateful is really a mindset that can have powerful health...
The Truth Behind 6 Of The Most Common Food Additives
Food: it's one of the most important contributors to your good health! It provides all the necessary nutrients for us to not only survive but thrive! It has fiber for a healthy digestive system, essential fats to keep inflammation at bay, and is a source of vitamins and minerals essential to the workings of our basic cellular functions.
Easy Ways To Improve Your Health With Nature
I've travelled the world seeking answers, optimal health and to find peace of mind. Whether it was bio-energetic sessions from my naturopathic doctor, meditating in India, a 10-day silent retreat in Thailand, or an Ayahuasca ceremony in Peru, there is always one thing that I am drawn back to... nature.When it comes to health, few things are as beneficial as being in nature.
The 3 Foods to Avoid for a Healthier Gut (and Why It Matters)
Gut bacteria—the trillions of microorganisms living in your digestive tract—may not be the sexiest subject, but it’s a hot topic in the health world lately. And for good reason: Over the past decade, research has brought to light how your gut microbiome (that's what science types call it) plays a role in almost every aspect of health, including digestion, immunity, fat storage, and heart health. The gut microbiota as an environmental factor that regulates fat storage. Bäckhed F, Ding H, Wang T.
5 Ways To Take Control Of Your Health At The Grocery Store
If I was to rummage through your kitchen cupboards right now what would I find? Would you gladly throw open your cabinets and fridge to show me a plethora of healthy produce, lean meats, and whole grains?
10 Reasons Why You Should Be Drinking Lemon Water
Drink more water! If only you had a glass of water every time you heard this sage wisdom you be... hydrated! The epitome of health advice, drinking more water can sometimes be easier said than done. Between keeping track of your water bottle, remembering to take a drink every hour, and the constant trips to the bathroom, getting your daily quota can have you feeling as though you're sinking rather than swimming.
Sick And Tired Of Trying To Look Good? It Might Be Your Cosmetics
There are times when I'm travelling so much that I'm thankful all the under-eye baggage I have is at least carry-on! Wan wan...Joking aside, don't we all just want to look good? Cosmetic and personal care is a billion dollar industry that caters to our need to smell good, look good, and feel good. On average women are directly exposed to 515 different chemicals daily in everything from cosmetics to lotions, fragrances, and styling products.
Control Your Coffee Addiction With 8 Simple Steps
Who's addicted to coffee? "Not ME," you say in an offended tone as you reach for your third double espresso of the day, and you're just getting started! Don't worry, I'm not about to ask you to quit your early cup of java. Believe it or not, I'm here to tell you that not all caffeine is bad for you; in fact, it's not bad for you at all!Sound too good to be true?
Send Seasonal Allergies Back Into Hibernation - Naturally
It's that time of year again! The crocuses are sprouting from their thawing terrain, the weather is slowly turning warmer, allowing us to shed our cocoons of winter clothing... is that sound of a robin I hear?
8 Reasons You'll Love Drinking Healthy Smoothies
It's tough to beat the benefits of a smoothie. Make a mean, green smoothie and it'll keep you super-charged all afternoon. Filled with fresh ingredients and tailored to your taste buds, they're especially good for those who:Hate to eat vegetables Are trying to lose weight Need a protein boost Rely on caffeine ... and even for those who are training hardMaybe you've already jumped on the smoothie bandwagon and are in fact drinking down a smoothie concoction of your own design right now?
What's The Best Shape For Your Poo?
Have you ever stopped to look at your poo?Is it small and round? Long and skinny? Does it break apart easily? Or is it chunky with bits of food?Did you know that the shape of your poo can tell you a whole lot about your health? Not only does the shape tell you a lot, but also the colour, smell, texture and quantity of your poo.The healthiest of poops is what I call "Mr. Happy." It has a smooth sausage shape that is effortless to pass, just think toothpaste.
The 4 Best Health And Life Tips For The Insanely Busy
I LOVE BEING BUSY, but busy doesn't often translate to productive. Being busy is great, but not if it lacks direction, passion, and makes your health suffer. While it's always important to focus on "the major players" of your health, including diet, exercise, sleep and stress management, these are broad categories and are easier said than done, especially when trying to fit them into your busy schedule.
The Health Effects Of 5 Different Kinds Of Alcohol
Alcohol has been ingested for thousands of years during celebrations and spiritual ceremonies, used in cooking, employed as an antiseptic and analgesic, and used in botanical tinctures to enhance their medicinal properties.However, modern day use has more and more people turning to alcohol for it's sedative effects to cope with anxiety and stress and to "let loose."Alcohol can actually be used as medicine when combined with certain plants, extracted properly and given at correct dosages for a...
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