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Asset Management Internal Revenue Code (IRC)

ASKramer Law

Business Taxation of Hedging Transactions Part II: Common Situations

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What is the “tax character” of a hedge? A taxpayer receives ordinary gain or loss on qualified hedges that have been properly identified in accordance with Treasury Regulation § 1.1221-2. This allows a taxpayer to ensure that...more

Gray Reed

Federal Income Taxation of Intellectual Property Development and Cost Recovery

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Intellectual property (“IP”) development can cost millions of dollars so cost recovery timing can be financially material. General tax principles typically require that expenses associated with creating assets having useful...more

Blank Rome LLP

Avoiding Zero Basis for Inherited Assets

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Practitioners involved with the administration of trusts and estates of a decedent may be confronted with the issue of dealing with one or more assets of a decedent discovered after the administration is believed to have been...more

Proskauer - Tax Talks

Tax Court holds that an offshore fund is engaged in a U.S. trade or business

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On November 15, 2023, the U.S. Tax Court held in YA Global Investments v. Commissioner that a non-U.S. private equity fund (YA Global) with a U.S. asset manager that bought equity and convertible debt of U.S. portfolio...more

Greenberg Glusker LLP

Top Tax and Legal Considerations for Wealthy Families Going Global

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In recent years, we have seen high net-worth and ultra-high-net-worth families become, increasingly, “global citizens.” As families and their assets touch multiple jurisdictions, a myriad of issues become especially important...more

Goulston & Storrs PC

Massachusetts Doubles Estate Tax Threshold as Part of $1 Billion Tax Reform Act

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On October 4, 2023, Massachusetts enacted a new law called “An Act to improve the Commonwealth’s competitiveness, affordability, and equity” (the “Act”). The Act makes several tax law changes relevant to Massachusetts...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

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Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Proskauer Rose LLP

Question of the Week: As infrastructure assets evolve, how has that presented new opportunities for investors?

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Infrastructure assets are going to remain highly attractive. This is partly because they offer all the characteristics that investors are looking for like long-term protection on revenues, decorrelation from economic cycles...more

ASKramer Law

Taxation of Derivatives Held by Investors: What to Know

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The taxation of derivatives and financial products has developed in an uncoordinated and piecemeal fashion. Tax rules have largely been enacted in response to what the government has perceived as abusive transactions —...more

Freeman Law

What is a Trust?

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Trusts - Trusts play an important role in estate and tax planning. A trust is a fiduciary arrangement that allows a trustee to hold legal title to assets for the benefit of a beneficiary. The beneficiary is, in turn, said...more

Foster Garvey PC

Opportunity Zone Funds – Part IV: The Second Round of Proposed Regulations

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On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more

Akin Gump Strauss Hauer & Feld LLP

Opportunity Zones: New Guidance Sheds Light on How Private Equity Industry Can Take Advantage

• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more

Dechert LLP

DOL “Investment Advice” FAQs: Considerations for Investment Advisers, Broker-Dealers and Insurance Companies

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The U.S. Department of Labor (DOL) issued in April 2016 the final version of its controversial “investment advice” regulation and various related exemptions (collectively, Final Rules), which are widely expected to have a...more

Troutman Pepper

Private Equity Fees and Expenses

Troutman Pepper on

In This Presentation: - Agenda - Typical Fund Structure - Typical Fund Waterfall - Fund Economics- Nuances - LPA Provisions - Fund Due Diligence - Legal Landscape - PEI...more

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