The Firm
Firm Culture
What Sets Us Apart?
Commitment to Community
Diversity and Inclusion
Freeman Foundation
Trial College
Professionals
Practice Areas
Bankruptcy
Corporate
Civil Litigation
Accounting Defense
Business Litigation
Business Divorce Litigation
Civil Litigation
Fiduciary Litigation
Minority Shareholder Litigation
Partnership Litigation
Digital Asset & Cryptocurrency Law
Nonprofits & Exempt Organizations
Outside General Counsel
Tax Litigation
Tax Litigation
Conservation Easement Defense
Criminal Tax Defense
FBAR Penalty Defense
International & Offshore Tax Compliance
IRS Penalty Defense
IRS Collections Defense
Micro-Captives
Streamlined
State Local Tax
Tax Court Litigation
Tax Shelter Litigation
Tax Promoter Defense
White-Collar
White-Collar
Cyber Crime Defense
Civil RICO Litigation
Forensic Accounting and Investigations
Healthcare Fraud
Intellectual Property
Money Laundering
Securities Fraud
Industries
Accounting Firms
Construction
Cross-Border
Energy
Family Offices
Finance and Banking
Government Sector
Healthcare
Investment Funds
Manufacturing
Nonprofits & Exempt Organizations
Private Equity
Real Estate
Startups and Emerging Companies
Technology
Trusts & Estates
Events
INTERNATIONAL TAX SYMPOSIUM 2021
INTERNATIONAL TAX SYMPOSIUM 2022
News
Recognition
Insights
Insights Blog
Videos
Podcast
Treaty Resources
Partnership Representatives and BBA Resources
Cryptocurrency and Blockchain Law Resources
Contact
Tax Controversy
Tax Controversy
Start With Who Is Writing the Check | The 2026 Attribution Change for Private Funds
By
Francisco Sanfiel
Sep 29, 2026
