On April 24, the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding Section 897. In December 2022, the IRS issued proposed regulations under Sections 897 (the Proposed Regulations) and 892...more
2023 saw a number of key tax developments that may affect the private fund industry going into 2024, from key US Tax Court opinions and updates to Internal Revenue Service (IRS) Forms, to new regulations proposed by the IRS...more
The Internal Revenue Service (IRS) recently ruled that if a taxpayer using a cash method of accounting stakes certain cryptocurrency and receives additional units of such cryptocurrency as rewards for staking, the taxpayer...more
The Internal Revenue Service (IRS) issued proposed regulations under Sections 892 and 897 of the Internal Revenue Code of 1986, as amended, on December 29, 2022. Final regulations under Section 897 regarding the exemption...more
The IRS recently provided relief from the RIC distribution requirement for money market funds that receive contributions in connection with the transition to a floating NAV, enabling RICs to top up their NAVs without having...more
5/24/2016
/ Diversification Requirements ,
Floating NAV ,
Income Taxes ,
Insurance Industry ,
Internal Revenue Code (IRC) ,
IRS ,
MMF ,
Money Market Funds ,
Registered Investment Companies (RICs) ,
RICs ,
Securities and Exchange Commission (SEC)
The Treasury and the IRS have delayed implementation of the recently announced rule change that treats certain types of upfront payments on swaps as loans for federal income tax purposes (including for purposes of the...more
10/15/2015
/ Comment Period ,
Debt Financing ,
Dodd-Frank ,
Exceptions ,
Income Taxes ,
IRS ,
Loans ,
Proposed Regulation ,
SIFMA ,
Swaps ,
Tax Exempt Entities ,
U.S. Treasury