News & Analysis as of

Asset Management International Tax Issues

Proskauer - Tax Talks

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

Proskauer - Tax Talks on

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

Akin Gump Strauss Hauer & Feld LLP

UK Spring Budget 2023: Points for Asset Managers

Introduction - On 15 March 2023, the UK government revealed the widely anticipated Spring Budget, which contained a number of measures that may be of interest to asset managers....more

Akin Gump Strauss Hauer & Feld LLP

UK Mini-Budget - Helpful for Asset Managers

The government’s 2022 Growth Plan, deceptively referred to as the “mini-budget,” has brought in notable changes likely to impact the funds industry. In particular, a number of the changes will help ensure the continued...more

McDermott Will & Emery

International News: Spotlight on Tax

INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more

Cadwalader, Wickersham & Taft LLP

EU Directive Targets 'Shell' Companies

On December 22, 2021, the European Commission published proposals for a Directive which targets the perceived misuse of “shell” entities for tax purposes. The draft of the Directive proposes a common minimum substance test...more

Katten Muchin Rosenman LLP

Qualifying Asset Holding Company: A New UK Taxation Regime

The new regime for asset holding companies (the qualifying asset holding company (QAHC) regime) was published last month as part of the draft Finance Bill 2021-22. In essence, the term 'asset holding companies' refers to...more

Cadwalader, Wickersham & Taft LLP

UK Asset Holding Companies: What Does the Future Hold?

The UK Government’s public consultation on Asset Holding companies (AHCs) has just finished, having run from December 15, 2020 to February 23, 2021. The objectives of the UK Government in the consultation have been to improve...more

Proskauer Rose LLP

The Arrival of Hong Kong’s Limited Partnership Fund Regime

Proskauer Rose LLP on

Hong Kong’s private funds industry is on the verge of benefitting from further significant changes in local laws designed to make Hong Kong more attractive as a centre for private funds and their managers. On 31 August 2020,...more

Dechert LLP

COVID-19: UK Tax Residence Risks for Offshore Funds and Related Entities

Dechert LLP on

Non-UK resident companies play a variety of roles in fund structures managed by UK based asset managers. They are commonly used as the fund vehicle itself, as the general partner of a limited partnership fund vehicle, and/or...more

McDermott Will & Emery

[Event] 2019 Tax In The City®: Seattle - October 24th, Seattle, WA

McDermott Will & Emery on

We invite you to join us for a discussion on current tax issues including: • Judicial deference and potential impact on TCJA audits • Developments and planning considerations for intangible assets o US tax...more

Holland & Knight LLP

A New Tax for an Economy in Crisis

Holland & Knight LLP on

The National Constituent Assembly (ANC) on July 2, 2019, issued the constitutional law that created the Wealth Tax (Impuestos a los Grandes Patrimonios). The creation of this tax reopens the debate on the constitutionality of...more

Fenwick & West LLP

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

Akin Gump Strauss Hauer & Feld LLP

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

Dechert LLP

Ticking all the Right Boxes! Irish Collective Asset Management Vehicles Act 2015 Signed into Law

Dechert LLP on

The eagerly anticipated Irish Collective Asset-management Vehicles Act 2015 (the “ICAV Act”) was signed into law in March 2015 and the first Irish Collective Asset-management Vehicles (“ICAVs”) have been authorised by the...more

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