The US Supreme Court’s decision in Mayo earlier this year caught the attention of tax professionals. George Hani and Alan Horowitz of Miller & Chevalier, Washington, DC, argue that the full impact of the case will depend on the outcome of a new case addressing whether deference is owed to a more aggressive effort by the IRS to issue regulations with retroactive effect.
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After joining Milbank from Akin Gump, the fund tax specialist discusses sponsor demand, practice building, and the tax challenges facing asset managers
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