Tag: U.S. trade


Tax Court holds that an offshore fund is engaged in a U.S. trade or business

January 3, 2024

Via: JD Supra

On November 15, 2023, the U.S. Tax Court held in YA Global Investments v. Commissioner that a non-U.S. private equity fund (YA Global) with a U.S. asset manager that bought equity and convertible debt of U.S. portfolio companies was engaged […]