Each one takes a live market event, finds the tax mechanism underneath it, walks the numbers, and ends with a view. Subscribe by email · RSS
When one household owns the hive and several households feed it, where should the return go?
The most personal thing we have written, and the second note with nothing to do with your K-1. It began with insomnia in 2020 and the English rules of beekeeping, and it runs from Justinian to a seventh-century Irish tract on bee stings, a Nuremberg beekeepers' guild with its own court and crossbows, the straw hives the English burned every autumn, and a disease that emptied Edwardian apiaries and may never have existed, through to this year's fights over pesticides, honey labels, and a hornet from France. Then, because we could not help ourselves, the tax: HMRC zero-rates the hire of honey bees and standard-rates the box they arrive in.
Apollo’s Torsten Slok finds no AI payoff yet outside the tech giants, and companies now call token spending a cost center. The tax code already shares that cost: every token is deductible, and tokens spent building new software can earn a research credit, if usage is tagged when it is consumed. We run the numbers on one $10 million model bill and set out four steps for year-end.
In Watson Lake, Del Monte, and Lontrac, the Tax Court adopted the government’s comparable sales, set aside cash flow models built on uses the land had no right to, disallowed $39.4 million outright on one clause in a deed, and left no reasonable cause defense to the 40 percent penalty. The reasoning reaches any discount, GRAT, or gift of property that rests on an appraisal.
Notice 2026-62 and a companion ruling treat the classic ETF seeding trade as taxable, with no prospective-only relief. The IRS acquiesced in Siemens, the November 7520 rate rose to 6.2%, the 871(m) phase-in runs through 2028, and crypto trusts, opportunity funds, and consolidated groups each got new rules. Seven items, in order of how much coffee they required.
Monroe Capital’s Ted Koenig calls PIK toggles and covenant-dodging extensions “silent default.” For the lender, PIK from day one is original issue discount, taxed as it accrues with no cash. On a $100 million loan, a partnership investor pays $16.5 million of tax over three years on interest never received, and a 60-cent settlement turns it into a capital loss.
The 10-year Treasury hit its highest level since 2002, buyers are retrading signed deals, and $875 billion of commercial and multifamily mortgages mature this year. We price the three exits (modify the loan, hand back the keys, or bring in rescue capital) partner by partner on one office building. A deed in lieu can hand an investor a $4 million tax bill on a building it no longer owns, and the rescue recap hides a chargeback that one clause in the operating agreement fixes.
On November 3, California votes on Proposition 40, a one-time 5% tax on the worldwide net worth of billionaires who were California residents on January 1, 2026. The residency date has already passed; what is still open is how private stock, carried interest, and trusts get valued, and what to do before December 31.
For a corporate owner, the number that sets the 2026 bill is 14 percent: the blended foreign rate, measured the U.S. way, at which credits cover the tax. Below it, the low-taxed plant writes the bill. We work one portfolio through the 2026 rules and set out three decisions for 2026 models.
A $10 million CLO equity investment pays $1 million of cash, ends the year marked at $9.5 million, and reports $1.4 million of taxable income. All three numbers can be right. Our special report follows the money from the issuer, through the fund, to the investor, and sets out what an approval package should require before the closing, the reset vote, or the exit.
Carlos Schmidt co-authored an op-ed in Bloomberg Law proposing a revenue-neutral, statutory fix to inflation-indexed capital gains, paired with a modest rate increase.
A Michigan county sold a family's $194,400 house at auction for $76,008 to collect $2,241.93 of unpaid property tax. Two years earlier the Court let the IRS add $889,914 of estate tax back onto a brother's life-insurance-funded buy-sell. Neither opinion reads like a tax treatise. Both decide who keeps the money. Our special report reads 2,890 of the Court's tax decisions, from 125 stipulated chariots in 1796 to this June, for the holdings that belong in your next agreement.
Beijing has given residents until October 22 to settle back tax on offshore trusts funded since 2023, and it is the sharpest example of a pattern visible on most continents, as governments reach for the people who have money through residence tests, deemed sales, and automatic data exchange rather than through the assets themselves.
On September 28 the IRS ruled that a §351 ETF conversion built on an integrated contribution-and-redemption plan is a taxable exchange, and flagged seven related fund strategies for comment by October 28. The holding reaches only the stock that left the fund, not the whole conversion, so the number that matters is the lot-level record, not the headline.
The AICPA and former IRS Commissioner Danny Werfel have launched a Council on AI Risk in Tax just as the agency leans harder on software with far fewer people to run it. A correct return can still be expensive to defend when a screen, or a newer examiner, cannot connect two numbers that were reported correctly all along.
A sponsor needs $100 million, the senior lenders will not advance it, and a capital-solutions fund offers a note or preferred stock that both appear to buy time. The price of that time is harder to see. We follow one hypothetical company, Northline Services, from financing to exit and land on three answers, one per seat at the table, none of them free, all of them negotiable if you catch them before the term sheet is signed.
Our first client note with nothing to do with your K-1. A history of art in transit, from the Doge of Venice's gilded ceremonial barge to the 32-foot fiberglass horse with glowing red eyes that guards Denver International (residents call him Blucifer; he has never lived it down). Along the way: stagecoach doors painted like small traveling galleries, a Calder mobile that survived a commissioner who thought it belonged in a museum instead of an airport (he was half right — the airport became one), and a Frank Stella painting bought for $25,000 that is now worth roughly $8 million, which is either the best art advice or the best financial advice we have ever accidentally given. One question follows the whole story: who paid for the art, and what did they think they were buying?
HMRC has put a named compliance manager on every billionaire it has identified with a UK tax connection, filer or not, and on November 3 Californians vote on a one-time 5% tax on billionaire net worth keyed to a residency date already behind us. The mobility data carry real labels, not the ones usually quoted, and the reference dates deserve attention while a proposal is still a proposal.
Investment funds and carried-interest vehicles can elect the pass-through entity tax, deduct it, and defend it. A state income tax is a §164 item, not a §212 expense, and nothing in §164, §703, the regulations, or Notice 2020-75 asks whether the partnership is in a trade or business. Two worked cases, a state-by-state eligibility table, and five questions to settle before you sign. A technical companion carries the reporting walkthrough, the allocation exhibits, and the answers to the objections.
A two-page reading of Stevens and Weinreich (EY), "Nor a Lender Be," Tax Notes Federal, September 2, 2026. Two factors decide whether a platform's origination work is attributed to a non-U.S. investor: influence over terms and the power to bind. Six market scenarios mapped, and what we would build the file around.
La Presa Partners served as tax adviser to Trimontium on a bespoke $325 million package of debt, hybrid, and equity instruments for Authentic Restaurant Brands, a portfolio company of Garnett Station Partners.
A CFO's guide to measuring a tax department: a mandate map, a five-dimension scorecard, ten principles (the tenth courtesy of the derivatives desk), the metrics to distrust, and a 100-point starting framework.
What the cashing-out LP, the rolling LP, and the new money each give up when a sponsor moves a company into a continuation vehicle, with the basis and liability arithmetic laid out step by step.
What a collateralized fund obligation is, why Franklin Templeton's first one matters more than its size, how the economics work through a simple example, and the questions an investor should ask before buying in, from waterfall position to valuation control to tax treatment.
On August 12 a divided Fifth Circuit panel withdrew its January Sirius Solutions opinion and substituted a management-based test for who counts as a "limited partner." The taxpayer kept its remand; everyone else lost a bright line. What changed, what it costs, and what sponsors should do now.
Get the alerts by email, about once a week.
One client alert most weeks, plus the occasional firm note. Unsubscribe in one click. Privacy notice