Is this you? As a journalist, you can create a free Muck Rack account to customize your profile, list your contact preferences, and upload a portfolio of your best work.
Claim your profile
Articles by Thomas Gray
IRS Puts Investment Fund Tax Strategies Under the Microscope: What Fund Managers Need to Know
Treasury and the IRS issued Notice 2026-62 and Revenue Ruling 2026-20 together, targeting Section 852(b)(6) ETF redemption strategies and “tax-aware” hedge fund structures as potentially abusive. Revenue Ruling 2026-20 already treats Section 351 ETF “conversion” transactions as taxable sales, meaning investors who used this strategy may owe tax now.
IRS Puts Investment Fund Tax Strategies Under the Microscope: What Fund Managers Need to Know
Treasury and the IRS issued Notice 2026-62 and Revenue Ruling 2026-20 together, targeting Section 852(b)(6) ETF redemption strategies and “tax-aware” hedge fund structures as potentially abusive. Revenue Ruling 2026-20 already treats Section 351 ETF “conversion” transactions as taxable sales, meaning investors who used this strategy may owe tax now.
Second Circuit Affirms That Active Fund Managers Cannot Escape Self-Employment Tax as 'Limited Partners' in Soroban Capital Partners | JD Supra
Key Points In Soroban Capital Partners LP v. Commissioner, the Second Circuit affirmed a functional test for the "limited partner" exception to self-employment tax under I.R.C. §1402(a)(13): a partner must not only enjoy limited liability but must also refrain from managing, controlling, or running the partnership's business.
Second Circuit Affirms That Active Fund Managers Cannot Escape Self-Employment Tax as ‘Limited Partners’ in Soroban Capital Partners
In Soroban Capital Partners LP v. Commissioner, the Second Circuit affirmed a functional test for the “limited partner” exception to self-employment tax under I.R.C. §1402(a)(13): a partner must not only enjoy limited liability but must also refrain from managing, controlling, or running the partnership’s business.
Fifth Circuit Narrows, but Preserves, Taxpayer-Favorable Ruling on Limited Partner Exception to Self-Employment Tax on Rehearing
The Fifth Circuit’s August 2026 opinion in K Alain, L.L.L.P. v. Commissioner (No. 24-60240) replaces its prior Sirius Solutions ruling and holds that a “limited partner” under 26 U.S.C. § 1402(a)(13) is a partner who plays no significant role in managing or running a business. The new opinion rejects both the Tax Court’s “passive investor” standard from Soroban Capital Partners LP v.
Fifth Circuit Narrows, but Preserves, Taxpayer-Favorable Ruling on Limited Partner Exception to Self-Employment Tax on Rehearing
We've updated our Privacy Statement. Before you continue, please read our new Privacy Statement and familiarize yourself with the terms.
Fifth Circuit Narrows, but Preserves, Taxpayer-Favorable Ruling on Limited Partner Exception to Self-Employment Tax on Rehearing
We've updated our Privacy Statement. Before you continue, please read our new Privacy Statement and familiarize yourself with the terms.
Tax Issues With M&A Representations, Warranties, and Indemnifications: Reps and Warranty Insurance, Proceeds — 2026
Representation and warranty provisions are critical components of M&A deals. The use of RWI has drastically changed the landscape of how these important deal terms are negotiated. Counsel and advisers must carefully consider these provisions and their financial and tax implications when structuring purchase agreements.
Fifth Circuit Narrows, but Preserves, Taxpayer-Favorable Ruling on Limited Partner Exception to Self-Employment Tax on Rehearing
The Fifth Circuit’s August 2026 opinion in K Alain, L.L.L.P. v. Commissioner (No. 24-60240) replaces its prior Sirius Solutions ruling and holds that a “limited partner” under 26 U.S.C. § 1402(a)(13) is a partner who plays no significant role in managing or running a business. The new opinion rejects both the Tax Court’s “passive investor” standard from Soroban Capital Partners LP v.
IRS Releases Proposed Regulations on Crypto Information Reporting
On March 5, 2026, the IRS issued proposed regulations (the Proposed Regulations) setting forth an alternative process for digital asset brokers to obtain consent from customers to receive Form 1099-DA statements electronically. This alternative process provided in the Proposed Regulations is meant to alleviate administrative tax compliance burdens for digital asset brokers.
Fifth Circuit Overturns Tax Court, Ruling in Favor of the Taxpayer in Case Evaluating Standard for Limited | JD Supra
Sirius Solutions is one of several cases in which the Tax Court had adopted the passive investor standard in favor of the government, and the Fifth Circuit’s rejection of the Tax Court’s approach is the first decision from a court of appeals on this issue.
The Role of Surety Bonds in Construction Projects | JD Supra
INTRODUCTION Surety bonds serve as a safeguard to ensure the fulfillment of contractual obligations and help owners manage the risks that come along with the construction industry. A surety bond is an agreement involving three different parties: the surety, the principal, and the obligee. Each party plays a vastly different role. The surety provides a guarantee to the obligee that the principal, typically a contractor, will fulfill their obligations per the terms of the contract.
IRS Provides Guidance for Trusts Engaged in Staking | JD Supra
On November 10, 2025, the IRS issued Rev. Proc. 2025-31 (the Rev Proc.), which provides a safe harbor for investment trusts and grantor trusts to stake certain digital assets without jeopardizing their status as trusts for U.S. federal income tax purposes. The Rev. Proc.
Restructuring & Insolvency Lawyer at Bennett Jones Toronto
Overview Thomas Gray has a general insolvency and restructuring practice. In his practice, Thomas acts for distressed companies, secured and unsecured creditors, court officers and other stakeholders in a variety of proceedings. Before becoming an associate at Bennett Jones, Thomas summered and articled with the firm. Related Services Education & Bar Admissions Education Queen's University, BA (Hons.), 2017, with distinction Queen's University, JD, 2020 Bar Admissions Ontario, 2021
Navigating AI-Driven Transformations in Equipment Leasing and Financing for the Transportation Sector | JD Supra
INTRODUCTION The rapid integration of artificial intelligence (AI) across industries is reshaping how businesses operate, particularly within the transportation sector. One area seeing significant transformation is equipment leasing and financing, where AI is redefining asset valuation, operational efficiencies, and legal frameworks. This article explores how legal professionals and stakeholders can navigate this evolving landscape.
The One Big Beautiful Bill: Initial Analysis of Key Provisions for Investment Funds and Sponsors | JD Supra
On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that could have significant consequences for both individuals and businesses. This alert summarizes certain key tax provisions of the Tax Bill for the investment funds industry and sponsors.
Crowdfund Investing: An Exciting Alternative for Individual Investors
Indexing and thoughtful asset allocation are solid choices for most individual investors’ core holdings. But for those seeking exceptional gains on a long-term investment horizon, alternative investments like private equity—including venture capital—can offer an uncorrelated, value-based, and often highly lucrative, complement to the otherwise staid 60% stock/40% bond investment plan.
SNDL Announces Successful Bid to Purchase Indiva
SNDL Inc. announced today that, in the context of proceedings pursuant to Indiva Limited's filing under the Companies' Creditors Arrangement Act (Canada) (the CCAA) and the sales process approved thereunder, the stalking horse bid of SNDL has been chosen as the successful bid in the acquisition of the Indiva Group, subject to approval by the Ontario Superior Court of Justice (Commercial List) overseeing the CCAA proceedings. Bennett Jones is acting as legal counsel to the Indiva Group.
Sometimes the Truth Hurts
Why does The Independent allow letter writers to spew lies? There are too many examples to list in the allotted space, so let’s sample one lie in particular: that the Biden administration and/or Kamala Harris (all by herself) “allowed 10 million illegals into the country.” This lie has been cited by a few letter writers, more notably by Dave Ott (twice) and Daniella Karo. It’s simply not true.
Effective Strategies for Handling Construction Defect Claims | JD Supra
In 2022, North Carolina was bustling with new construction projects, ranking as the sixth highest state for newly built homes. With so much building going on, construction defect claims are bound to pop up. These claims can affect everyone in the industry—from contractors and builders to architects. So, it’s essential to know how to handle them. Understanding Construction Defects Imagine you’ve just finished a major home renovation. The owners move in, and everything seems perfect.
Will Modifying the Terms of a Debt Instrument Result in a Taxable Transaction? - Creditor’s Rights Toolkit | JD Supra
When a borrower struggles to meet the payment obligations of a debt instrument, the borrower and creditor may work together to modify some of the terms to give the borrower a little breathing room or provide the creditor with more security. The parties may agree to change the interest rate, extend the repayment period, change collateral, or make a variety of other modifications to the debt instrument.
Will Modifying the Terms of a Debt Instrument Result in a Taxable Transaction?
When a borrower struggles to meet the payment obligations of a debt instrument, the borrower and creditor may work together to modify some of the terms to give the borrower a little breathing room or provide the creditor with more security. The parties may agree to change the interest rate, extend the repayment period, change collateral, or make a variety of other modifications to the debt instrument.
How Can I Claim a Business Bad Debt Deduction? | JD Supra
The Internal Revenue Code permits a business bad debt deduction when a customer fails to pay for the services rendered or the products supplied by your business. However, the ability to claim an ordinary deduction with respect to the worthless debt depends on a variety of factors, and you should be ready to substantiate your position if the IRS ever challenges it. This article addresses the key issues to claiming a business bad debt deduction in a bankruptcy case.
How Can I Claim a Business Bad Debt Deduction?
Businesses can claim a bad debt deduction under the Internal Revenue Code when a customer fails to pay for services or products. However, the ability to claim this deduction depends on several factors, and businesses should be prepared to substantiate their claim if challenged by the IRS. The key issues discussed include the requirement of a debtor-creditor relationship, the type of debt, the basis for the debt, and the timing of the deduction.
How Can I Claim a Business Bad Debt Deduction?
The Internal Revenue Code permits a business bad debt deduction when a customer fails to pay for the services rendered or the products supplied by your business. However, the ability to claim an ordinary deduction with respect to the worthless debt depends on a variety of factors, and you should be ready to substantiate your position if the IRS ever challenges it. Key Issues Deduction.
Tax Court Rules That Limited Partners May Be Subject to Self-Employment Tax | JD Supra
Summary On November 28, the Tax Court, granting the Internal Revenue Service (IRS) summary judgment, held in Soroban Capital Partners LP v. Commissioner that a state law limited partner who is limited in name only, is not exempt from self-employment taxes under the limited partner exception found in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the Code). Rather, the court found that, for this purpose, a functional inquiry of the interest is required.
Tax Court Rules That Limited Partners May Be Subject to Self-Employment Tax
Summary On November 28, the Tax Court, granting the Internal Revenue Service (IRS) summary judgment, held in Soroban Capital Partners LP v. Commissioner that a state law limited partner who is limited in name only, is not exempt from self-employment taxes under the limited partner exception found in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the Code).
Rolling Over and Section 704(c); What’s the Big Deal? — Part 4: The Remedial Method | JD Supra
In our continuing series on Section 704(c) of the Internal Revenue Code (the Code) we discuss the application of the remedial method to correct for distortions caused by the ceiling rule.
Rolling Over and Section 704(c); What's the Big Deal? — Part 3: The Traditional Method With Curative Allocations | JD Supra
Continuing with our series on the implications of the application of Section 704(c), the below discussion addresses the use of the traditional method with curative allocations. In Part 1 [insert link] we gave a broad overview of Section 704(c) and its application to property that is contributed to a partnership, where the contributor's tax basis in the property differs from the fair market value of the property (the built-in gain or built-in loss).
Rolling Over and Section 704(c); What's the Big Deal? — Part 2: The Traditional Method | JD Supra
In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner.
Rolling Over and Section 704(c); What's the Big Deal? — Part 1: The Basics | JD Supra
When entering into a partnership agreement where one partner is contributing cash and another partner is contributing appreciated property, inevitably, a tax advisor is going to ask, which Section 704(c) allocation method does the partnership want to use? For the business folks, this may lead to some head scratching and the ultimate question of why would I care?
FIRPTA and Publicly Traded Corporations | JD Supra
On May 19, 2023 the Internal Revenue Service (IRS) released AM 2023-003 (the Memo or GLAM) holding that the Foreign Investment in Real Property Tax Act's (FIRPTA's) 5% publicly traded exception (the 5% exception) applies at the partnership level and not at the partner level, potentially subjecting the partnership to additional reporting and withholding requirements with respect to its non-U.S. partners, and subjecting the non-U.S. partner to U.S. federal income taxes and reporting obligations.
Request for information regarding the Prime Minister's knowledge of information about the Australian music group 'This Is Serious Mum' - a Freedom of Information request to Prime Minister
OFFICIAL Reference: PM/23/027 Dear Mr Gray The purpose of this email is to acknowledge the request you made to the Prime Minister’s Office (PMO) for access under the Freedom of Information Act 1982 (the Act). The Department of the Prime Minister and Cabinet (PM&C) provides administrative support to the PMO for the processing of their Freedom of Information (FOI) requests. We have forwarded your request to the PMO for consideration.
New IRA Tax Incentives for US Manufacturing in Renewable Energy Sector | JD Supra
On August 16, President Biden signed the Inflation Reduction Act of 2022 (IRA) into law, which includes landmark tax incentives for domestic energy production and manufacturing with the goal of reducing carbon emissions in the United States by roughly 40% by 2030.
Vista medical records
Hello all, Let me start by saying thank you in advance for any help or information provided. Quick backstory: The first time I filed was in May of 2012(I lived in El Paso, Tx at the time), it was for PTSD, bursitis in hips, carpal tunnel, and a slew of other joint problems, however life happened and I missed a C&P exam that I was unaware of and the claim was denied at the beginning of 2013.
COVID-19 Liquidity Requirements Eased by IRS for Publicly Offered RICs and REITs
You are responsible for reading, understanding and agreeing to the National Law Review's (NLR’s) and the National Law Forum LLC's Terms of Use and Privacy Policy before using the National Law Review website. The National Law Review is a free to use, no-log in database of legal and business articles. The content and links on www.NatLawReview.com are intended for general information purposes only.
IRS Eases Liquidity Requirements for Publicly Offered RICs and REITs | 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.
Asset Diversification Test: A Timely Refresher | 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.
Vibrational exciton nanoimaging of phases and domains in porphyrin nanocrystals
Vibrational exciton nanoimaging of phases and domains in porphyrin nanocrystals Eric A. Muller, Thomas P. Gray, Zhou Zhou, Xinbin Cheng, Omar Khatib, Hans A. Bechtel, Markus B. Raschke Proceedings of the National Academy of Sciences Mar 2020, 201914172; DOI: 10.1073/pnas.1914172117
IRS Proposes New Regulations for Determining Whether Foreign Insurance Companies Are PFICs | 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.
Qualified REIT Dividends Paid by RICs are Eligible for the Code Section 199A Deduction
You are responsible for reading, understanding and agreeing to the National Law Review's (NLR’s) and the National Law Forum LLC's Terms of Use and Privacy Policy before using the National Law Review website. The National Law Review is a free to use, no-log in database of legal and business articles. The content and links on www.NatLawReview.com are intended for general information purposes only.
EU moves towards its own crypto-asset regime
Reports from Esma and the EBA suggest that the EU is moving closer to creating its own regime for regulating crypto-assets potentially forcing member states, which take an early lead in this area, to revise their own crypto rules. By Katerina Katsiami, associate in Harneys regulatory practice in Cyprus, and Thomas Gray, senior associate in Harneys banking and finance practice in the Cayman Islands.
Fire destroys house with moonshine still in basement
Sullivan County Sheriff's deputies are investigating a house fire in Blountville,{ }Tennessee after renters set up a moonshine still in the basement without the owner's knowledge. (Photo credit: WCYB)BLOUNTVILLE, Tenn. - Sullivan County Sheriff's deputies are investigating a house fire in Blountville, after renters set up a moonshine still in the basement without the owner's knowledge.Homeowner Vernon Rollers said the renters never told him the house was on fire.
Fire destroys house with moonshine still in basement
Sullivan County Sheriff's deputies are investigating a house fire in Blountville,{ }Tennessee after renters set up a moonshine still in the basement without the owner's knowledge. (Photo credit: WCYB)BLOUNTVILLE, Tenn. - Sullivan County Sheriff's deputies are investigating a house fire in Blountville, after renters set up a moonshine still in the basement without the owner's knowledge.Homeowner Vernon Rollers said the renters never told him the house was on fire.
Fire destroys house with moonshine still in basement
Sullivan County Sheriff's deputies are investigating a house fire in Blountville,{ }Tennessee after renters set up a moonshine still in the basement without the owner's knowledge. (Photo credit: WCYB)BLOUNTVILLE, Tenn. - Sullivan County Sheriff's deputies are investigating a house fire in Blountville, after renters set up a moonshine still in the basement without the owner's knowledge.Homeowner Vernon Rollers said the renters never told him the house was on fire.
Fire destroys house with moonshine still in basement
Sullivan County Sheriff's deputies are investigating a house fire in Blountville,{ }Tennessee after renters set up a moonshine still in the basement without the owner's knowledge. (Photo credit: WCYB)BLOUNTVILLE, Tenn. - Sullivan County Sheriff's deputies are investigating a house fire in Blountville, after renters set up a moonshine still in the basement without the owner's knowledge.Homeowner Vernon Rollers said the renters never told him the house was on fire.
Fire destroys house with moonshine still in basement
Sullivan County Sheriff's deputies are investigating a house fire in Blountville,{ }Tennessee after renters set up a moonshine still in the basement without the owner's knowledge. (Photo credit: WCYB)BLOUNTVILLE, Tenn. - Sullivan County Sheriff's deputies are investigating a house fire in Blountville, after renters set up a moonshine still in the basement without the owner's knowledge.Homeowner Vernon Rollers said the renters never told him the house was on fire.
Fire destroys house with moonshine still in basement
Sullivan County Sheriff's deputies are investigating a house fire in Blountville,{ }Tennessee after renters set up a moonshine still in the basement without the owner's knowledge. (Photo credit: WCYB)BLOUNTVILLE, Tenn. - Sullivan County Sheriff's deputies are investigating a house fire in Blountville, after renters set up a moonshine still in the basement without the owner's knowledge.Homeowner Vernon Rollers said the renters never told him the house was on fire.
After a House Fire: Restoring your Home Without Losing Your Mind.
Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: Already signed up? Log in here By using the service, you signify your acceptance of JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources.
MATCH REPORT: Hyde United 2-2 Colne
Both teams come away with a deserved point as an enthralling game of contrasting halves comes to an end. Hyde came into the game having not scored in their last three games however they have only conceded one goal in that time in their loss to Lancaster. Colne came into the game on the back of two defeats but there confidence was high due to their impressive away record.
Show More
loading
Actions
Is this you?
As a journalist, you can create a free Muck Rack account to customize your profile, list your contact preferences, and upload a portfolio of your best work.Get in touch with Thomas
Contact Thomas, search articles and posts on X, monitor coverage, and track replies from one place.
Learn more about Muck Rack