Publications Memos Go Back IRS Liberalizes Regulations Defining the Scope of a Plan Under section 355(e) 05.06.02 This memorandum addresses new temporary and proposed IRS regulations that define the scope of a plan under section 355(e) of the Internal Revenue Code. Related Insights 06.24.25 | Publications Senate Bill Pulls Some Punches, but Would Still Phase Out Tax Credits for Future Clean Energy Projects 06.18.25 | Publications The Senate Finance Committee’s Proposed Section 899 Would Increase Taxes on Certain Foreign Individuals and Entities Majority-Owned by Such Individuals 05.30.25 | Publications Tax Court Finds Management Company Limited Partners Do Not Qualify for the Self-Employment Tax Exception Related Services Related Practice Areas Corporate Tax