Under current (post-2017) federal income tax law, long-term capital gain allocated to or realized by a non-corporate recipient of a promote or other performance-based allocation (a "Carried Interest") in the investment...more
As part of the US federal tax reform in 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended (the "Code"), to provide incentives economic growth and investment in designated...more
4/24/2019
/ Anti-Abuse Rule ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Opportunity Zones ,
Partnerships ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Transactions ,
S-Corporation ,
Safe Harbors ,
Tangible Property ,
U.S. Treasury
Beginning in 2018, partnerships (meaning an entity treated as a partnership for tax purposes) generally are subject to the new partnership audit rules. Partnerships may elect out of the new partnership audit rules if they (1)...more
On October 31, the Internal Revenue Service (IRS) released proposed regulations (the "Proposed Regulations") under Section 956 that could substantially increase the collateral packages made available by US corporate borrowers...more
11/6/2018
/ Controlled Foreign Corporations ,
Corporate Financing ,
Dividends ,
Domestic Corporations ,
GILTI tax ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Section 956 ,
Shareholders ,
Subsidiaries ,
U.S. Treasury
On October 19, the Internal Revenue Service (IRS) and US Department of the Treasury released the first set of proposed regulations under Internal Revenue Code Subchapter Z—Opportunity Zones (Proposed Regulations). On the same...more
10/23/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Planning ,
U.S. Treasury
Katten previously alerted our readers to the changes in partnership audit rules [See Katten Advisory, "New Partnership Audit Regime Set to Take Effect in 2018, Proactive Planning Recommended," August 7, 2017]. The Internal...more
The recently enacted "Tax Cuts and Jobs Act of 2017" (P.L 115-97) (the "Act") made, among others, significant changes to the rules that govern whether taxpayers can deduct as business expenses certain settlement payments made...more
On November 2, 2015, Congress passed the new centralized partnership audit regime as part of the Bipartisan Budget Act of 2015 (BBA) which is set to take effect for the tax years beginning on or after January 1, 2018. The...more
In a traditional private equity fund, the fund managers will raise money from investors to establish a pool of capital the fund can then use to invest in a number of portfolio companies. A big benefit of a fund is that the...more
On July 29, Windstream announced that it plans to spin off certain telecommunications network assets into an independent, publicly traded real estate investment trust (REIT). Windstream made the announcement after it obtained...more
On March 25, the Internal Revenue Service (IRS) issued Notice 2014-21 (notice) containing guidance and frequently asked questions relating to virtual currencies such as bitcoins. Among other clarifications, the notice states...more