For the sixth consecutive year, Dechert is the contributing editor of the International Comparative Legal Guide - Private Equity. The guide, now in its tenth edition, is one of the most comprehensive comparative guides to...more
9/10/2024
/ Competition ,
Debt Financing ,
France ,
Interest Rates ,
Leveraged Buyout ,
Presidential Elections ,
Price Inflation ,
Private Equity ,
Regulatory Standards ,
UK ,
Valuation
On August 12, 2022, the U.S. Congress passed the Inflation Reduction Act of 2022 (the “Act”), which was signed into law by President Biden on August 16, 2022. Alongside sweeping changes to energy, environmental and...more
8/26/2022
/ Alternative Minimum Tax ,
American Rescue Plan Act of 2021 ,
Business Losses ,
CARES Act ,
Corporate Taxes ,
Excise Tax ,
Fair Market Value ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
New Legislation ,
Publicly-Traded Companies ,
Shareholders ,
Stock Repurchases ,
U.S. Treasury
U.S. Senate Finance Committee Chair Ron Wyden (D-Ore.) and Senator Sheldon Whitehouse (D-R.I.) on August 5, 2021, introduced legislation entitled the “Ending the Carried Interest Loophole Act” (the “Wyden Bill”)....more
The White House has released several tax proposals, culminating with remarks by President Biden in a Congressional address. These proposals include the American Families Plan, for which the White House released a fact sheet...more
The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) on July 31, 2020 issued long-awaited proposed regulations (the “Proposed Regulations”) providing guidance under section 1061...more
8/13/2020
/ Capital Gains ,
Carried Interest ,
Fund Managers ,
IRS ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
REIT ,
RICs ,
S-Corporation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On Friday 8 May 2020, the European Commission announced a proposal to postpone by three months the initial reporting deadlines for “DAC6”, the incoming mandatory disclosure regime for potentially aggressive tax arrangements....more
5/15/2020
/ Coronavirus/COVID-19 ,
Cross-Border Transactions ,
Deferred Action ,
EU ,
European Commission ,
Filing Deadlines ,
Financial Institutions ,
Mandatory Disclosure Rules ,
Member State ,
Reporting Requirements ,
Time Extensions ,
UK
Below please find a list of global tax measures in response to COVID-19.
United States -
On March 25 and March 27 the U.S. Senate and House of Representatives, respectively, passed the Coronavirus Aid, Relief and...more
In the wake of the Coronavirus pandemic, on March 18, 2020 the U.S. Internal Revenue Service issued guidance extending the Federal income tax payment deadline for any person with a Federal income tax payment otherwise due...more
The UK government yesterday announced that it will introduce a targeted Digital Services Tax aimed at large search engines, social media platforms and online marketplaces, applicable from April 2020. ...more
The Opportunity Zone program created by the Tax Cuts and Jobs Act of 2017 (the “TCJA”) allows taxpayers that realize certain gains to elect to defer the federal income tax on such gains by reinvesting them into Qualified...more
10/24/2018
/ Business Taxes ,
Capital Gains ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning
President Trump signed into law tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”) on December 22, 2017. The Tax Act implemented the most far-reaching changes to the Internal Revenue Code (the...more
4/9/2018
/ Base Erosion Tax ,
Business Expenses ,
Capital Gains ,
Carried Interest Tax Rates ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Exports ,
GILTI tax ,
Global Market ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
Local Taxes ,
Multinationals ,
Net Operating Losses ,
Pass-Through Entities ,
Portfolio Companies ,
Private Equity ,
Private Equity Funds ,
Repatriation ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Exemptions ,
Tax Rates ,
Trump Administration
A recent U.S. Tax Court case, Grecian Magnesite (149 T.C. No. 3, July 13, 2017), has declared invalid the long-standing U.S. government position that a non-U.S. person’s sale of an interest in a partnership (in this case, a...more
7/19/2017
/ Capital Gains ,
Foreign Investment ,
Foreign-Owned Corporations ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Non-Resident Income Taxes ,
Partnership Interests ,
Partnerships ,
Reversal ,
Tax Court ,
Transfer of Interest
The U.S. Treasury Department and the Internal Revenue Service (the “IRS”) have re-issued proposed regulations (the “Proposed Regulations”) on the new centralized partnership audit rules enacted as part of the Bipartisan...more
6/22/2017
/ Audits ,
Bipartisan Budget Act ,
Business Taxes ,
C-Corporation ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
S-Corporation ,
TEFRA ,
Trump Administration ,
U.S. Treasury
All eyes are on Washington—or should we say Manhattan—these days, searching for clues about where our ship is heading with U.S. President-elect Donald Trump at the helm. Recently, there have been cabinet appointments to...more
1/6/2017
/ Affordable Care Act ,
Capital Gains ,
Clean Water Act ,
Corporate Taxes ,
Deregulation ,
Dodd-Frank ,
Energy Sector ,
Financial Stimulus ,
Foreign Investment ,
Fossil Fuel ,
Infrastructure ,
Initial Public Offering (IPO) ,
Merger Controls ,
National Security ,
Pass-Through Entities ,
Permits ,
Private Equity ,
Repeal ,
Tax Reform ,
Trump Administration ,
Volcker Rule
New rules recently proposed by the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) would re-characterize purported debt instruments as equity instruments, and could have significant implications...more
India and Mauritius entered into a Protocol amending the double-tax treaty between India and Mauritius (the “2016 Protocol”) on May 10, 2016. Under the 2016 Protocol, following a grace period and subject to a grandfather...more
There has been buzz in the tax and private equity communities about the rise in audits of private equity firms by the Internal Revenue Service (“IRS”). This has been fueled by the restructuring of the IRS’ Large Business &...more
Congress recently amended the rules governing tax audits of partnerships that file U.S. partnership returns, including U.S. partnerships (and limited liability companies treated as partnerships) and certain non-U.S....more
The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”), signed into law on December 18, 2015, has resulted in a number of changes to the taxation of investments in U.S. real property by foreign investors. Among...more
Proposed regulations were issued under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the “Code”), that address circumstances when certain arrangements between partnerships and their partners will be...more
The Internal Revenue Service (“IRS”) and Treasury Department issued Notice 2014-52 (the “Notice”) targeting corporate inversions on September 22, 2014 (the “Notice Date”) in the U.S. Tax considerations are important for...more
The U.S. Department of Justice (“DOJ”) established a Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”) on August 29, 2013. The Program is intended to facilitate a resolution with the...more