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Secondary U.S. Withholding for Transfers in Private Investment Funds Delayed Until January 1, 2023

Key Points - Fund-level liability for a buyer’s failure to withhold upon secondary market transfer of an LP interest in a fund with ECI assets will apply only for transfers on or after January 1, 2023. Certain...more

BBA Tax Audits: Final Deadline for Designating a U.S. Partnership Representative

• U.S. and non-U.S. investment funds that are required to file, or file, a U.S. partnership tax return (Internal Revenue Service (IRS) Form 1065) are generally subject to a new U.S. partnership audit regime that permits the...more

Carried Interest and Other Tax Reform Highlights for Investment Funds and Asset Managers

• Significant corporate and potential individual tax rate reductions and a 25% individual tax rate on certain “qualified business income” would be introduced (although many fund investors and sponsors would not be eligible...more

Treasury Delays Implementation of Final Expanded Dividend-Equivalent Regulations By Two Years, Keeps Current Four-Factor Test in...

The Department of the Treasury and the Internal Revenue Service (IRS) announced today (available here) that they are delaying the implementation by two years—until January 1, 2016—of final expanded regulations governing the...more

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