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Southgate Master Fund LLC v. United States

taxprof.typepad.com/files/southgate.pdf

Sep 30, 2011 ... plaintiff, Southgate Master Fund, L.L.C., was formed for the purpose of ... A partnership for tax purposes, Southgate's disposition of its portfolio.

Southgate Master Fund: The Sham Partnership Doctrine Gets Messy ...

taxblawg.net/2011/12/13/southgate-master-fund-the-sham-partnership-doctrine-gets-messy-or-does-it/

Dec 13, 2011 ... Two weeks ago, the Fifth Circuit summarily rejected a taxpayer request for an en banc rehearing in Southgate Master Fund LLC v. United ...

Justice Department Prevails in Three Tax Shelter Cases on Same Day

www.justice.gov/opa/pr/justice-department-prevails-three-tax-shelter-cases-same-day

Oct 4, 2011 ... In Southgate Master Fund LLC v. United States, the U.S. Court of Appeals for the Fifth Circuit, based in New Orleans, affirmed a lower court ...

Texas Billionaire Beal And Feds Reach Deal On DAD-dy Of All Tax ...

www.forbes.com/sites/janetnovack/2014/04/11/texas-billionaire-beal-and-feds-reach-deal-on-dad-dy-of-all-tax-refunds/

Apr 11, 2014 ... ... from the 5th Circuit ruled on Beal's first case—a 2002 tax return filed by Southgate Master Fund LLC. In their decision, the judges nixed Beal's ...

Southgate Master Fund v. United States - Robbins, Russell, Englert ...

www.robbinsrussell.com/sites/default/files/appellate_pdf/southgate-master-fund-v.-united-states-reply.pdf

SOUTHGATE MASTER FUND, L.L.C., by and through Montgomery Capital. Advisors, LLC its Tax Matters Partner,. Plaintiff-Appellant Cross-Appellee, v. UNITED ...

Tax Shelters: The Ninth Circuit Reverses a Grant of Summary ...

taxcontroversyposts.postschell.com/a-sham-partnership-case/

Aug 7, 2015 ... Id., slip op. at *2-*3 (reversing Broadwood Inv. Fund LLC v. ... Id., slip op. at *25, the case that it relied upon, Southgate Master Fund, LLC v.

Tax MVP: Dentons' Todd Welty - Law360

www.law360.com/articles/601828/tax-mvp-dentons-todd-welty

Dec 4, 2014 ... Securing Southgate Master Fund LLC a rare 97 percent concession from the IRS of nearly $300 million and first-chairing the Schaeffler Group's ...

December 2011 - PwC

www.pwc.com/us/en/tax-services-multinationals/newsletters/mergers-and-acquisitions/assets/pwc-this-month-ma-december-2011.pdf

Proposed regulations defining "interest in a limited partnership as a limited partner". Southgate Master Fund LLC v. United States: Fifth Circuit denies rehearing ...

Current Developments in Partners and Partnerships - The Tax Adviser

www.thetaxadviser.com/issues/2012/feb/burton-feb12.html

Jan 31, 2012 ... The same issue arose in Home Concrete & Supply LLC. ..... Southgate Master Fund LLC's disposition of its portfolio of NPLs generated more ...

The Future of Tax Planning? - Steptoe & Johnson LLP

www.steptoe.com/assets/attachments/4112.pdf

funds is no different than a dividend to the parent shareholder, and should be taxed accordingly. This regime, known as .... Southgate Master Fund LLC et al. v.

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SOUTHGATE MASTER FUND LLC v. UNITED STATES OF ...

caselaw.findlaw.com

Sep 30, 2011 ... Case opinion for US 5th Circuit SOUTHGATE MASTER FUND LLC v. UNITED STATES OF AMERICA. Read the Court's full decision on ...

CA 7 8/26/2013

media.ca7.uscourts.gov

Aug 26, 2013 ... Petaluma FX Partners, LLC v. Commissioner, 591 F.3d. 649, 651 (D.C. Cir. 2010) ; see also Southgate Master Fund,. L.L.C. v. United States ...

IRS Wins Tax Shelter Trifecta - Forbes

www.forbes.com

Oct 10, 2011 ... Image via hendrick.com The Justice Department announced victories in three tax shelter cases at once: Southgate Master Fund LLC v. United ...