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New Accredited Investor Rules Will Expand Eligibility for Private Fund Investments

On August 26, 2020, the SEC adopted several changes to expand the definition of an “accredited investor.” For the first time, a new category will enable natural persons to qualify as accredited investors based upon their...more

Fund Managers and Family Offices Get Some Clarity on Carried Interests with Issuance of Proposed Treasury Regulations

On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more

New IRS Deadline for Additional Taxpayers, Plus Relief for Like-Kind Exchanges and Qualified Opportunity Zone Fund Investments

As we reported in our previous client alert, "Federal and State Tax Actions in Response to COVID-19," the IRS has extended until July 15, 2020, the deadline for filing income, gift and GST tax and information returns, and...more

Federal and State Tax Actions in Response to COVID-19

We believe the following tax developments are of particular interest to our clients. Tax Return Filing Extensions - The 2019 federal income tax return filing deadline is extended to July 15, 2020, for individuals,...more

Owners of Foreign Business Interests – BEA Reports Have Not Been Extended

Every five years, the Bureau of Economic Analysis (BEA) requires "U.S. Reporters" of certain foreign business interests to submit surveys on Form BE-10. This year the surveys, or requests for extension, must be submitted by...more

Tax Savings in the Paycheck Protection Program

The Coronavirus Aid, Relief, and Economic Security Act (CARES) Act authorizes the Small Business Administration to make loans to allow "small businesses" to continue their payroll, and provides for cancellation of the loans...more

The CARES Act Offers a New Tax Planning Opportunity

One provision of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) involves a "real estate" tax break, which is actually much broader and applies to many taxpayers, and may require the filing of amended tax...more

Client Alert: Purchases of Partnership and LLC Interests Adversely Affected by Newly-Proposed Regulations Under Code Section 199A

Historically, we have advised clients that it is no less advantageous, from a federal income tax perspective, to acquire a partnership interest (including a membership interest in an LLC taxed as a partnership) than it would...more

Maximizing Deductions Through Prepayment of Real Property Taxes Before Potential Tax Law Changes

Currently, individual taxpayers who itemize their deductions can deduct real property taxes paid that year. Under both the House and Senate tax reform bills, the property tax deduction would be capped at $10,000. If that cap...more

New IRS Rules for Partnership Audits Require Immediate Review of Partnership Agreements

Beginning in 2018, most partnerships (including LLCs and other arrangements treated as partnerships for tax purposes) will be subject to a new “centralized partnership audit regime.” The volume of Internal Revenue Service...more

Energy Transfer, Williams, and the Circular Ownership of Stock

It is unheard of for a deal to die at the closing table because lawyers cannot deliver a required opinion regarding a transaction that they structured and negotiated. Yet, this is exactly what happened last year when two...more

Treasury Proposes Regulations That Would Require Private Trust Companies to Establish or Enhance AML Programs and to Identify...

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published proposed regulations on August 25, 2016 that would require certain private trust companies utilized by high net worth individuals,...more

IRS Issues Guidance to Partnerships Opting-In to New Partnership Audit Regime

The Internal Revenue Service (IRS) issued temporary regulations on August 4, 2016, providing the time, form and manner for partnerships to elect to apply the new partnership audit regime enacted by the Bipartisan Budget Act...more

SEC Sends Warning to General Partners of Funds Receiving Finders’ and Other Fees

On June 1, 2016, the SEC sent a warning to general partners of private investment funds (including private equity funds, hedge funds, venture capital funds and leveraged buyout funds) by entering into a settlement agreement...more

Impending Deadline for Bureau of Economic Analysis Surveys May Cause Unprepared U.S. Companies to Be Subject to Penalties

Every five years, the U.S. Bureau of Economic Analysis of the U.S. Department of Commerce (BEA) conducts a “benchmark” survey regarding U.S. direct investment abroad by country and industry. The purpose of the survey is to...more

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