As we previously reported, following the tax reform package passed in December, private equity limited partner investors based outside the United States are now subject to tax on gains from the sale of partnership interests....more
4/27/2018
/ Capital Gains ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Partnership Interests ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
Withholding Tax
More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more
3/19/2018
/ Capital Gains ,
Foreign Investment ,
Income Taxes ,
IRS ,
Limited Partnerships ,
Partnership Interests ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Trump Administration ,
Withholding Tax
Private equity and venture capital funds often invest in portfolio companies that are formed as partnerships or limited liability companies. But these investments create certain problems for foreign limited partners (LPs) in...more