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International Comparative Legal Guide – Private Equity 2024

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

Inflation Reduction Act of 2022: Corporate Alternative Minimum Tax, Excise Tax on Corporate Stock Repurchases, and Business Loss...

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

Getting Carried Away with Carried Interest Reform: U.S. Senate Finance Committee Chair Ron Wyden Introduces the “Ending the...

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

Biden 2021 Tax Proposals: Individuals & Corporations

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

Proposed Carried Interest Regulations: Treasury Carries the Ball, Giving Precious Few Points to Fund Managers

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

EU Commission proposes extension of the DAC6 reporting deadlines

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

COVID-19 Coronavirus: Global Tax Update

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

COVID-19 Coronavirus: Tax Payment Deadline Extended Amidst Outbreak (1)

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

UK Commits to Introducing Targeted Digital Services Tax

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

IRS Issues Regulations Clarifying Opportunity Zones and Opportunity Funds

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

Newsflash: Tax Court Reverses IRS Revenue Ruling

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

Reissuance of Proposed Regulations on Partnership Audit Rules

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

Global Private Equity Newsletter - Winter 2017 Edition: President Trump: The Outlook for Private Equity

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

Global Private Equity Newsletter - Summer 2016 Edition: New Proposed Regulations Increase Scrutiny on Related-Party Debt

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

Recent Indian Tax Treaty Changes Affecting Nonresident Investments into India - Termination of Capital Gains Exemption under the...

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

Partnership Audits of Private Equity Firms on the Rise

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

Global Private Equity Newsletter - Spring 2016 Edition: Recent Changes to Rules Governing Tax Audits of Partnerships

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

PATH Act Creates New FIRPTA Withholding Tax Rate and Exemption for Foreign Pension Funds

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

Global Private Equity Newsletter - Fall 2015 Edition: Proposed Partnership Treasury Regulations – Consider the Guaranteed Payment

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 New Landscape for Inversions: IRS and Treasury Change the Rules

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

U.S. Department of Justice Awaits Swiss Banks’ Voluntary Disclosure of Banking Activities

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

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