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First Department Extends Common Interest Privilege

In a decision sure to affect the behavior of parties in transactional and other contexts, the New York Appellate Division for the First Department on December 4, 2014 eliminated the “pending or reasonably contemplated litigation” requirement from the common interest privilege. Thus, the presence of a third party at an otherwise privileged communication will not…

Client Alerts | December 9, 2014

IRS Issues Chief Counsel Advice on Self-Employment Tax

Overview On September 5, 2014, the IRS released a Chief Counsel Advice (ILM 201436049), which discusses the application of self-employment tax to members of a limited liability company providing investment management services. The CCA concludes that all members of the limited liability company (the “LLC”) are subject to self-employment tax on their distributive shares of…

Client Alerts | September 10, 2014 | Securities and Corporate Finance | Hedge Funds