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
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
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
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
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
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
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
1/11/2018
/ Corporate Taxes ,
Energy Sector ,
Mortgage REITS ,
Multinationals ,
Net Operating Losses ,
Private Investment Funds ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
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
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
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
2/9/2016
/ Anti-Money Laundering ,
Audits ,
CFTC ,
Chief Compliance Officers ,
Conflicts of Interest ,
Cybersecurity ,
FinCEN ,
Fund Managers ,
IRS ,
National Futures Association ,
Popular ,
Private Equity ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury ,
Volcker Rule ,
Year-End Compliance Checklist
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