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U.S. Withholding on Synthetic Trades over U.S. Equities (Section 871(m)) – Additional Delay of Full Implementation until 2023

• The broader application of Section 871(m) has again been delayed, this time until January 1, 2023 and as a result, investment funds with non-U.S. feeders or investors up the chain should generally expect to incur U.S....more

BBA Tax Audits: Final Deadline for Designating a U.S. Partnership Representative

• U.S. and non-U.S. investment funds that are required to file, or file, a U.S. partnership tax return (Internal Revenue Service (IRS) Form 1065) are generally subject to a new U.S. partnership audit regime that permits the...more

Latest Opportunity Zone Rules Clarify Issues Related to Fund Structuring, Qualifying Businesses and Business Property

• The latest set of proposed opportunity zone (OZ) regulations (the “2019 proposed regulations”) provide much-needed flexibility with regard to qualified opportunity funds (“OZ Funds”) and expand the types of businesses and...more

Carried Interest and Other Tax Reform Highlights for Investment Funds and Asset Managers

• Significant corporate and potential individual tax rate reductions and a 25% individual tax rate on certain “qualified business income” would be introduced (although many fund investors and sponsors would not be eligible...more

Comprehensive Overhaul of Partnership Audit Regime

On November 2, 2015, the Bipartisan Budget Act significantly overhauled the audit regime applicable to U.S. and certain non-U.S. investment fund vehicles that are taxed as partnerships for U.S. federal income tax purposes. In...more

11/12/2015  /  Audits , Bipartisan Budget , IRS , Partnerships , TEFRA

FATCA — Final Deadline to Obtain a GIIN for Model 1 IGA FFIs

Under transitional relief, certain non-U.S. investment funds, including Cayman Islands funds, that qualify as foreign financial institutions (FFIs), have been permitted to certify their status under the U.S. Foreign Account...more

IRS Internal Memorandum Advises That Self-Employment Tax Applies to Profits From an Investment Manager

On September 5, 2014, the Office of Chief Counsel, Internal Revenue Service (IRS) released an internal generic legal advice memorandum advising an IRS field agent that the statutorily provided “limited partner” exception to...more

FATCA Implementation Further Delayed Until July 1, 2014, FFIs Should Finalize Registrations by April 25, 2014

The Internal Revenue Service (IRS) issued Notice 2013-43 (available here), which delays by six months certain of the timelines during which withholding agents and foreign financial institutions (FFIs) will be required to...more

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