On 29 December 2022, President Biden signed into law the SECURE Act 2.0 (SECURE 2.0) as part of the Consolidated Appropriations Act of 2023. SECURE 2.0 builds on the 2019 passage of the Setting Every Community Up for...more
On 10 September 2021, Senate Finance Committee Chairman Ron Wyden of Oregon released a discussion draft proposing changes to partnership taxation, and to the taxation of regulated investment companies including mutual funds...more
There is little doubt that the outcome of the 3 November federal election will be consequential for much of America, and that the consequences are likely to be very different depending on who sits in the Oval Office and the...more
Depending on the results of the presidential and congressional elections in November 2021 could usher in major changes in tax policy. You should be thinking about those potential changes now for purposes of 2020 year-end tax...more
In response to the economic havoc resulting from the onset of the coronavirus (“COVID-19”) pandemic, Congress has enacted wide-ranging legislation to help keep businesses open and to help borrowers and lenders deal with debts...more
The Tax Cuts and Jobs Act (“Act”) significantly changed U.S. tax federal law. Although the Act does not amend any of the provisions directly affecting the qualification or other taxation of a “regulated investment company”...more
On March 8, 2017, the staff of the Securities and Exchange Commission (“SEC”) granted no-action relief that potentially will permit global investment management firms to offer U.S. registered open-end management investment...more
The Treasury Department (Treasury) and the Internal Revenue Service (Service) recently issued proposed regulations that, if finalized as proposed, could have a significantly adverse effect on the ability of a regulated...more
On July 23, 2014, the Securities and Exchange Commission adopted amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended, governing the structure and operation of money market mutual funds (MMFs). ...more
U.S.-registered investment companies (“RICs”) historically have had limited success attracting investments from non-U.S. investors, in large part due to U.S. withholding taxes on fund distributions. This has allowed funds...more
A recent Ninth Circuit Court of Appeals opinion charts potential new pathways for claims for damages resulting from portfolio losses by mutual fund shareholders against both a fund’s trustees and its investment adviser....more
The Internal Revenue Service has issued Revenue Ruling 2014-18 (the “Ruling”) to clarify that stock options and stock-settled stock appreciation rights (“SARs”), properly designed, can be used as a form of compensation to...more