The Corporate Transparency Act (CTA) is going into effect on 1 January 2024 and will mandate the disclosure of certain information related to beneficial owners and controllers of most US domestic entities and certain non-US...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
On 7 October 2020, the Treasury Department and the Internal Revenue Service (IRS) released final regulations under Code Section 1446(f) (the Final Regulations), which clarify aspects of the withholding requirements with...more
In light of the U.S. presidential election on 3 November 2020, many investors and business owners expecting a liquidity event are focused on the possibility that the current capital gains rate (generally, 23.8 percent) could...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
Prior to 2017 Tax Cuts and Jobs Act (TCJA), private equity fund, hedge fund, and other investment fund or asset managers that received an interest in an entity taxed as a partnership for U.S. federal income tax purposes (a...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
On 28 August 2020, the IRS issued eagerly awaited guidance on the implementation of the employee FICA payroll deferral authorized in a Presidential Memorandum (the Memorandum) signed by President Trump on 8 August 2020....more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
Many businesses have been evaluating their eligibility for various benefits in the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act. Two popular incentives include the Paycheck Protection Program (“PPP”) and the...more
On May 12, 2020, the Federal Reserve Bank of New York (the “Fed”) released its initial draft of frequently asked questions (the “Initial FAQs”) relating to the Term Asset-Backed Securities Loan Facility program (“TALF 2.0”)...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
Several weeks have passed since Congress passed two major legislative packages focused on providing liquidity for businesses and individuals, and keeping workers employed during the COVID-19 pandemic. The Families First...more
On May 12, 2020, the Federal Reserve Bank of New York (the “Fed”) released its initial draft of frequently-asked questions (“FAQs”) relating to the Term Asset-Backed Securities Loan Facility program under the CARES Act (“TALF...more
Recent legislation under the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) modifies several tax provisions in the Internal Revenue Code (the Code) to provide relief to businesses and individuals from the...more
Treatment of mortgage loan forbearances and modifications for mortgage loans in REMICs and fixed investment trusts - Throughout the United States, state and local governments have ordered various businesses to close in...more
In response to the economic havoc resulting from the onset of the coronavirus (“COVID-19”) pandemic, Congress has enacted wide-ranging legislation to help keep businesses open and to help borrowers and lenders deal with debts...more
The tax code could play a key role as discussions about a tax stimulus package intensify -
The coronavirus has taken over Washington, D.C., if not through infection, then through a focus on policy prescriptions to help the...more
Almost exactly two years after enactment in the Tax Cuts and Jobs Act, Treasury has released final regulations on the Opportunity Zone (“OZ”) tax incentive. ...more
DEVELOPMENTS IN SEEDING ARRANGEMENTS – OVERVIEW -
- Seeding Arrangements Fall Along a Spectrum, with Features Including:
- Making a Significant Capital Commitment to a Fund Manager at the Initial Closing of the Fund
-...more