The IRS recently issued an internal memorandum to the effect that many Name-Image-Likeness (NIL) collectives will not qualify for 501(c)(3) tax-exempt status, including those that had previously obtained tax exemption letters...more
As the pace of SPAC IPOs continues to set records, evolution of the economic terms has accelerated. We have seen changes to the warrant and promote structure (including “tontine” warrants), call rights motivating cashless...more