On November 28, 2023, in Soroban Capital Partners LP v. Commissioner, the US Tax Court denied the taxpayer’s motion for summary judgment, holding that whether a limited partner in a state law limited partnership qualifies for...more
We are often asked, by both new and established managers, “where should I form my next venture capital fund”? We will hold the short list for purposes of this article at the discussion of Delaware versus Cayman, those being...more
On July 13, 2017, the US Tax Court issued a decision which may provide non-US investors more flexibility and potentially better tax outcomes with respect to structuring their investments into US LLCs and partnerships....more
This alert highlights near-term regulatory deadlines that commonly apply to venture capital and private equity firms. For a more detailed description of regulatory and contractual requirements that commonly apply to venture...more
On October 13, 2016, the IRS and the Treasury Department issued new rules largely designed to prevent highly related corporate taxpayers from claiming the tax benefits of “earnings stripping,” or the payment of excessive...more