UK Financial Insights from Katten is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds in the UK and Europe....more
Katten Named Leader in Blockchain and Cryptocurrency in Chambers FinTech 2023 Guide -
Katten announced that the firm had attained a superior ranking in the Chambers FinTech 2023 guide. Katten was recognized as a leader in...more
Digital asset investment among proprietary trading firms, family offices, and asset managers peaked in the fall of 2021, dipped a bit in the summer of 2022, and now it’s on the rise again — even with the turbulence in the...more
Under current (post-2017) federal income tax law, long-term capital gain allocated to or realized by a non-corporate recipient of a promote or other performance-based allocation (a "Carried Interest") in the investment...more
On March 27, the United States Congress passed the Coronavirus Aid, Relief, and Economic Security Act or CARES Act, and the President signed the bill into law. The CARES Act provides for $2 trillion in economic stimulus and...more
Beginning in 2018, partnerships (meaning an entity treated as a partnership for tax purposes) generally are subject to the new partnership audit rules. Partnerships may elect out of the new partnership audit rules if they (1)...more
On October 31, the Internal Revenue Service (IRS) released proposed regulations (the "Proposed Regulations") under Section 956 that could substantially increase the collateral packages made available by US corporate borrowers...more
11/6/2018
/ Controlled Foreign Corporations ,
Corporate Financing ,
Dividends ,
Domestic Corporations ,
GILTI tax ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Section 956 ,
Shareholders ,
Subsidiaries ,
U.S. Treasury
Katten previously alerted our readers to the changes in partnership audit rules [See Katten Advisory, "New Partnership Audit Regime Set to Take Effect in 2018, Proactive Planning Recommended," August 7, 2017]. The Internal...more
The "official" House tax reform bill was released by the House Ways and Means Committee on November 9. For the most part, the provisions summarized in Katten's advisory, "Tax Reform: Hedge Funds/Commodity Funds/Fund...more
11/16/2017
/ Alternative Minimum Tax ,
Carried Interest ,
Commodities ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Deferred Compensation ,
Fund Managers ,
Hedge Funds ,
Pending Legislation ,
Self-Employment Tax ,
Tax Deductions ,
Tax Rates ,
Tax Reform
House Republicans released their draft tax bill on November 2, representing their opening bid in the drive to reach agreement on a comprehensive tax reform bill that can be presented to the House for a vote before the...more
11/9/2017
/ Alternative Minimum Tax ,
Corporate Taxes ,
Deferred Compensation ,
Hedge Funds ,
Income Taxes ,
Investment Funds ,
Investment Management ,
Pass-Through Entities ,
Proposed Legislation ,
Tax Rates ,
Tax Reform
On November 2, 2015, Congress passed the new centralized partnership audit regime as part of the Bipartisan Budget Act of 2015 (BBA) which is set to take effect for the tax years beginning on or after January 1, 2018. The...more
Included as a revenue offset in the budget legislation (H.R. 1314) signed by President Obama are provisions that simplify the procedure for the Internal Revenue Service to audit and collect adjustments from partnerships. The...more
SEC/CORPORATE -
SEC Proposes Amendments to Rules 147 and 504 -
On October 30, the Securities and Exchange Commission proposed amendments to modernize: (1) Rule 147, promulgated under the Securities Act of 1933...more
The US Department of the Treasury has issued regulations with respect to withholding on “dividend equivalent” payments made to a non-US long party on swaps and other financial instruments that are linked to US equities. These...more
BROKER-DEALER -
FINRA Requests Comment on Revised Price Disclosure Information Standards for Corporate and Agency Debt Securities -
The Financial Industry Regulatory Authority issued a regulatory notice...more
10/19/2015
/ AIFM ,
Alternative Investment Fund Managers Directive (AIFMD) ,
Broker-Dealer ,
CFTC ,
Commodity Exchange Act (CEA) ,
Debt Securities ,
Disclosure Requirements ,
Dividends ,
EU ,
European Commission ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Regulatory Reform ,
Investment Funds ,
NFA ,
No-Action Relief ,
OCC ,
Proposed Regulation ,
Swaps ,
Withholding Tax
On September 14, the Internal Revenue Service (IRS) issued final regulations under Internal Revenue Code Section 851 clarifying that control groups under the regulated investment company (RIC) rules may consist of two...more
On September 22, the Securities and Exchange Commission proposed a comprehensive package of rule reforms designed to enhance effective liquidity risk management by open-end funds, including mutual funds and exchange-traded...more
9/30/2015
/ Asset Class ,
Board of Directors ,
Comment Period ,
ETFs ,
Independent Director ,
Investment Company Act of 1940 ,
Investment Funds ,
Liquidity Risk Management Rule ,
Mutual Funds ,
NAV ,
Proposed Regulation ,
Registration Statement ,
Securities and Exchange Commission (SEC)
SEC/CORPORATE -
SEC Advisory Committee on Small and Emerging Companies Makes Recommendations -
On September 23, the Securities and Exchange Commission Advisory Committee on Small and Emerging Companies (Advisory...more
9/28/2015
/ ACH Payments ,
Asset Diversification ,
Banking Sector ,
Broker-Dealer ,
CFTC ,
Derivatives ,
Derivatives Clearing Organizations ,
Emerging Growth Companies ,
FDIC ,
Financial Conduct Authority (FCA) ,
Finders ,
Investment Funds ,
IRS ,
Mutual Funds ,
Registration Requirement ,
Rule 147 ,
SEC Advisory Committee ,
Securities and Exchange Commission (SEC) ,
Supervision ,
U.S. Treasury ,
UK
A recent response by the Internal Revenue Service Chief Counsel (CCA) to an inquiry from one of its field office agents addressed the question of whether management fees earned by an investment manager organized as a limited...more
In this issue:
- Council of Institutional Investors Issues Report on Board Evaluation Disclosure
- FINRA Revises Proposal to Adopt Consolidated FINRA Rule 2231
- IRS Considers Whether Management Fees of...more
9/22/2014
/ Broker-Dealer ,
CFTC ,
Corporate Governance ,
Dodd-Frank ,
EU ,
Financial Industry Regulatory Authority (FINRA) ,
Insider Trading ,
Institutional Investment ,
IRS ,
Limited Liability Company (LLC) ,
Margin Requirements ,
Swaps
On July 29, Windstream announced that it plans to spin off certain telecommunications network assets into an independent, publicly traded real estate investment trust (REIT). Windstream made the announcement after it obtained...more
On March 25, the Internal Revenue Service (IRS) issued Notice 2014-21 (notice) containing guidance and frequently asked questions relating to virtual currencies such as bitcoins. Among other clarifications, the notice states...more