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Final Carried Interest Regulations: Key Takeaways for Private Fund Sponsors

While the final regulations simplify key exceptions and contain favorable changes, ambiguity continues for investment fund managers. On January 7, 2021, the US Treasury Department and Internal Revenue Service (together,...more

Proposed Carried Interest Regulations Leave Unanswered Questions

While the proposed carried interest regulations clarify key aspects, the proposed rules leave some ambiguity for investment fund managers. Section 1061 is intended to limit long-term capital gain treatment attributable to...more

Tax Considerations for Financing and Refinancing Transactions in Turbulent Times

Volatile trading markets and economic instability may prompt taxpayers to modify, purchase, or repurchase debt; participants should consider the tax consequences. Key Points: ..Issuers may incur immediate income in the...more

IRS Issues Guidance on Transfers by Non-US Partners of Interests in Partnerships With US Assets

Proposed regulations under Section 864(c)(8) provide guidance for determining a foreign partner’s effectively connected gains or losses from a transfer of its interest in a partnership engaged in a US trade or...more

Withholding Guidance Issued on Sale of Interests in a Partnership with US Assets

The guidance shows Treasury Regulations will ease administrative challenges and exclude certain transfers from the new withholding regime. Key Points: ..Taxpayers can deliver IRS Form W-9 or an affidavit to establish...more

Private Equity Fund Managers: Annual Compliance Reminders and New Developments

Summary of private equity firms’ compliance obligations, discussion of notable developments in 2017, and outlook for 2018. US federal laws and regulations, as well as the rules of self-regulatory organizations (SROs),...more

US Tax Reform: Key Business Impacts, Illustrated With Charts and Transactional Diagrams

Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context. Key Points: ..The legislation alters fundamental aspects of US business taxation...more

How US Tax Reform Proposals Will Affect Private Investment Funds and Asset Managers

Aspects of the current proposals could significantly alter the US taxation of investment funds, sponsors, and investors. Key Points: ..Major changes to US tax laws on business tax rates, interest deductibility, and...more

Marketing Non-US Private Equity Funds in the United States

A roadmap through the various regulations and tax implications can help ensure a successful offering. Non-US private equity sponsors frequently seek to market their funds to US institutional investors. However, the...more

Private Equity Fund Managers: Annual Compliance Reminders and New Developments

Summary of private equity firms’ compliance obligations, discussion of notable developments in 2015 and outlook for 2016. US federal laws and regulations, as well as the rules of self-regulatory organizations (SROs),...more

IRS Issues Proposed Regulations Addressing Management Fee Waivers

Certain arrangements would be recharacterized as ordinary income, rather than as distributive shares of partnership income. On July 22, 2015, the US Treasury Department and the US Internal Revenue Service (IRS) released...more

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