Eric Sloan Explores Disguised Sales and Disguised Fees for Services Change with Tax Notes

In the Media  |  May 28, 2025

Tax Notes


Partner Eric Sloan spoke to Tax Notes about a last-minute change in the tax bill passed recently by the U.S. House of Representatives, which clarifies whether partnership rules on disguised sales and disguised fees for services are self-executing. While unexpected, Eric noted that the change may have limited practical impact.

“The subchapter K crowd has essentially practiced as if the [section 707] rules were operative in the absence of regulations for a long time, largely because we have all believed that a court would use one of many routes to reach the same result, even if a court found the code provision not to be self-executing,” he told the publication.

Eric is a Co-Chair of our firm’s Tax Practice Group.

Read more (registration required): https://www.taxnotes.com/tax-notes-today-federal/budgets/house-adds-tweak-partnership-disguised-sale-statute/2025/05/27/7s7z7