On April 24, the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding Section 897. In December 2022, the IRS issued proposed regulations under Sections 897 (the Proposed Regulations) and 892...more
A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a...more
The Internal Revenue Service (IRS) issued proposed regulations under Sections 892 and 897 of the Internal Revenue Code of 1986, as amended, on December 29, 2022. Final regulations under Section 897 regarding the exemption...more
US Senators Joe Manchin and Chuck Schumer announced on July 27 an agreement in principle on a legislative proposal, known as the Inflation Reduction Act of 2022, that includes a range of measures addressing consumer energy...more
Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more
3/9/2021
/ Corporate Taxes ,
Financial Services Industry ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Investment Management ,
IRS ,
Private Investment Funds ,
Sovereign Wealth Funds ,
Tax Assessment ,
Tax Evasion ,
Tax Liability
The Internal Revenue Service recently released Revenue Ruling 2020-27 and Revenue Procedure 2020-51, which provide guidance on the deductibility of certain expenses paid or incurred in a taxpayer’s business using loan...more
12/7/2020
/ Business Expenses ,
CARES Act ,
Coronavirus/COVID-19 ,
Federal Loans ,
IRS ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
SBA Lending Programs ,
Tax Deductions ,
Tax Planning ,
Tax Relief
The Internal Revenue Service (IRS) and the US Treasury Department released proposed regulations (REG-107213-18) under Section 1061 on July 31 providing guidance to the holders of certain carried interests. These rules are of...more
8/7/2020
/ Capital Gains ,
Carried Interest Tax Rates ,
Financial Services Industry ,
IRS ,
Partnership Interests ,
PFIC ,
Private Investment Funds ,
S-Corporation ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
Revenue Procedure 2020-22 from the Internal Revenue Service provides helpful flexibility for taxpayers in a real property trade or business. ...more
The Internal Revenue Service announced that it has revised the Employer Identification Number application process in order to provide greater security and improve transparency. The revision will require that each applicant’s...more
The proposed modifications would create opportunities for enhanced CFC credit support.
On October 31, 2018, the US Treasury Department and the Internal Revenue Service (IRS) released proposed Treasury Regulations (the...more
US Tax Court decision may facilitate tax-efficient investment structures for non-US investors investing in US operating partnerships, directly or through investment funds....more
The regulations affect both real estate investment trusts (REITs) and regulated investment companies (RICs) that receive appreciated property from a C corporation in a so-called “conversion transaction.”...more
The IRS notice further eases, but does not delay, FATCA implementation.
On May 2, the Internal Revenue Service (IRS) published Notice 2014-33 (the Notice), which announced that calendar years 2014 and 2015 will be...more
Foreign financial institutions, such as offshore funds, should register with the IRS by May 5 and review new and revised IRS forms.
The July 1 start date for Foreign Account Tax Compliance Act (FATCA) withholding on...more