At this point, private equity firms are very conscious that debt of their U.S. acquisition vehicles or portfolio companies cannot be guaranteed by controlled foreign corporations (CFCs), nor can more than 65 percent of the...more
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
Where asset acquisitions or deemed asset acquisitions are not available, the loss of the interest deduction would likely result in an increased focus on pure equity-funded transactions.
Originally published on the Middle...more
The proposal to eliminate the interest deduction may have a material adverse impact on U.S. middle-market companies.
In March, Republican presidential candidate Senator Marco Rubio, together with Senator Michael Lee,...more
Pepper partners Gregory J. Nowak and Steven D. Bortnick presented a webinar for West LegalEdCenter discussing issues that affect private funds and their managers.
Over the hour program, Mr. Nowak and Mr. Bortnick covered a...more
On February 26, 2014, U.S. Rep. David Camp (R-MI), chairman of the House Ways and Means Committee, released a draft of the Tax Reform Act of 2014 (TRA 2014), which would provide for the most significant tax reform since the...more