Adrienne Baker

Adrienne Baker

Dechert LLP

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Latest Publications


Section 871(m) Dividend Equivalent Guidance Including New Transition Relief Expected After Mid-November

The U.S. Internal Revenue Service (the “IRS”) plans to release a guidance package including final rules and transition relief for dividend equivalent transactions described in Section 871(m) of the U.S. Internal Revenue Code...more

10/25/2016 - Derivatives Dividends Equity Swaps Equivalency Determinations Internal Revenue Code (IRC) IRS Qualified Derivatives Dealers (QDDs)

Partnership Audits of Private Equity Firms on the Rise

There has been buzz in the tax and private equity communities about the rise in audits of private equity firms by the Internal Revenue Service (“IRS”). This has been fueled by the restructuring of the IRS’ Large Business &...more

4/1/2016 - Audits Bipartisan Budget Business Taxes IRS Management Fees Partnerships Private Equity Firms

Global Private Equity Newsletter - Spring 2016 Edition: Recent Changes to Rules Governing Tax Audits of Partnerships

Congress recently amended the rules governing tax audits of partnerships that file U.S. partnership returns, including U.S. partnerships (and limited liability companies treated as partnerships) and certain non-U.S....more

3/30/2016 - Audits Business Taxes IRS Partnerships Private Equity

Navigating the New Partnership Audit Rules: Sea Change or Same Course?

The recently enacted Bipartisan Budget Act of 2015 amended existing Internal Revenue Code of 1986, as amended (the “Code”) rules governing tax audits of partnerships in the U.S. These new rules primarily impact partnerships...more

2/2/2016 - Audits Bipartisan Budget Internal Revenue Code (IRC) IRS Operating Agreements Partnerships

The Common Reporting Standards - New Global Tax Information Exchange Regime Begins January 2016

The Common Reporting Standard (“CRS”) will impose new investor due diligence and reporting obligations on funds and other financial institutions based in “early adopter” participating jurisdictions, with effect from January...more

11/11/2015 - Common Reporting Standard (CRS) Cross-Border Transactions Due Diligence FATCA Financial Institutions Information Sharing International Tax Issues Investment Funds OECD UK

A Sea Change for Waive-rs? - Proposed Regulations Address Tax Treatment of Management Fee Waivers

The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) have issued proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the “Code”), covering the...more

8/17/2015 - Business Taxes Fee Waivers IRS Management Fees Partnerships Profits Interests Safe Harbors Significant Entrepreneurial Risk (SER) Treasury

Revised Timeline for Implementing FATCA

Sections 1471 through 1474 of the U.S. Internal Revenue Code (“FATCA”) generally impose a 30% withholding tax on certain payments to a foreign financial institution (“FFI”) unless the FFI has entered into an agreement with...more

7/16/2013 - Bank Accounts Banks FATCA FFI IGAs Internal Revenue Code (IRC) IRS U.S. Treasury

Financial Services Quarterly Report - First Quarter 2013: FATCA: Next Steps for Asset Managers

The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released final regulations (“Regulations”) on January 17, 2013 implementing the Foreign Account Tax Compliance Act (“FATCA”).1...more

3/27/2013 - Asset Management Due Diligence FATCA FFI Intergovernmental Agreements IRS U.S. Treasury Withholding Requirements

Significant Changes Made in Final FATCA Regulations

On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “Regulations”) implementing foreign account reporting provisions of the...more

2/11/2013 - Collateralized Debt Obligations Due Diligence FATCA Foreign Financial Accounts GIIN Intergovernmental Agreements Investment Funds IRS Portal Required Documentation U.S. Treasury Withholding Requirements

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