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Capital Gains Investment Management

Rivkin Radler LLP

New York Can Be Stingy Giving Credit – Resident Tax Credit, That Is

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The Office of the New York State Comptroller just released a new report that examines taxpayer migration trends during the pandemic. The report, which builds on an earlier analysis of pre-pandemic taxpayer migration trends,...more

Whitman Legal Solutions, LLC

Changes to Tax on Carried Interests Would Lead to Conflicts of Interest

Politicians are touting a new tax proposal they claim would "close the carried interest loophole." The tax proposal wouldn't eliminate carried interests as implied—it would only extend the holding period from three to five...more

McDermott Will & Emery

Inflation Reduction Act & Long-Term Capital Gain for Carried Interest

OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more

Clark Hill PLC

Congress Proposes Changes to the Taxation of Carried Interest

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On July 27, the Senate reached a deal that would raise taxes on carried interest income earned by investment managers. If enacted, the Inflation Reduction Act of 2022 (the “Act”) would amend the relatively new Section 1061...more

Neal, Gerber & Eisenberg LLP

Fund Managers and Family Offices Get Some Clarity on Carried Interests with Issuance of Proposed Treasury Regulations

On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more

BCLP

Private Wealth - Horizon Scanning 2020

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With a number of changes affecting the private wealth world to come over the next 12 months, our private client team take a look at some of the key UK legal developments for 2020, including the extension of the UK trust...more

K&L Gates LLP

Session II - Private Fund Developments: 2019 Boston Investment Management Conference

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RECENT SEC ENFORCEMENT ACTIONS - FEES AND EXPENSE ALLOCATIONS - ECP Manager (Sept. 27, 2019) Administrative Proceeding File No. 3-19535 - - A PE adviser settled claims which alleged that it caused its fund to overpay...more

K&L Gates LLP

Investments in Opportunity Zones: 2019 Seattle Investment Management Conference

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OUR AGENDA - - Why you need to know about Opportunity Zones - What you need to know about Opportunity Zones after two rounds of regulations - Policy - Definitions - Mechanics - What kinds of deals are we seeing? Structuring...more

Ballard Spahr LLP

Is Private Equity “Ready for Warren?

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Massachusetts Senator and presidential hopeful Elizabeth Warren released perhaps the most ambitious plan the country has ever seen with respect to regulation of the private equity and investment fund industry. She released...more

Foster Garvey PC

Opportunity Zone Funds – Part II: Due Diligence Required

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As with any investment, due diligence is required. Investing in an Opportunity Zone Fund (“OZF”) is not any different. Historically, we have seen taxpayers go to great lengths to attain tax deferral. In some instances, the...more

Proskauer Rose LLP

UK Tax Round Up - March 2018

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Welcome to the March edition of the Proskauer UK Tax Round Up. As promised, the Spring Statement from the Chancellor focused on the economy and public finances without any major tax announcements. However, a few interesting...more

Perkins Coie

New Three-Year Hold Requirement for Carried Interests

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The 2017 Tax Cuts and Jobs Act (the Act), signed by President Trump last month, significantly affects the ability of the managers of investment funds to receive long-term capital gains with respect to their carried interest....more

Hogan Lovells

Italy passes new rules for carried interest

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The Italian Government has at last put an end to the controversy around the characterisation of 'carried interest' for tax treatment purposes. By Law Decree no. 50 of 24 April 2017, which is to be brought into law by 23 June...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

Proskauer Rose LLP

UK 2015 Summer Finance Bill Update: Proposed Taxation Changes for Carried Interest and DIMF

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Further to our client alert in July this year, the UK Government recently proposed further changes to the UK taxation of carried interest and disguised investment management fees (DIMF). The UK Government proposed...more

K&L Gates LLP

SEC Enforcement Actions Against Investment Advisers

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According to the SEC’s most recent financial report, as of August 2014, SEC-registered investment advisers managed $62.3 trillion in assets. Not surprisingly, investment advisers attract a great deal of attention from the...more

Dechert LLP

Global Private Equity Newsletter - Fall 2015 Edition: The Summer Budget – Changes to the UK Tax Treatment of Carried Interest

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The Chancellor of the Exchequer’s recent Summer Budget and the related legislation introduced a series of unexpected tax changes along with the promise of further changes to come. Shortly after the Summer Budget was issued...more

Morrison & Foerster LLP

Changes in the UK Tax Treatment of Carried Interest

In the recent Summer Budget, the Chancellor announced that with immediate effect, there would be changes to the way that carried interest is taxed. In technical terms, the “base cost shift” which enabled an investment manager...more

Katten Muchin Rosenman LLP

Summer Budget 2015––Carried Interest: Abolition of Base Cost Shift

On July 8, the Right Honourable George Osborne MP, Chancellor of the Exchequer, introduced measures in his Summer Budget to abolish what is commonly known as the “base cost shift” as applied to sums received by individuals...more

Proskauer Rose LLP

UK Summer Budget 2015 – Key Issues for Asset Managers and Non-UK Domiciled Individuals

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On 8th July 2015, the UK Government announced several changes to UK tax legislation that will affect those holding carried interest in fund structures which utilise at least one partnership (including a limited partnership),...more

Dechert LLP

The UK Summer Budget - Private Equity and Investment Management

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The Chancellor of the Exchequer’s Summer Budget on 8th July introduced a series of unexpected tax changes affecting the private equity and investment management industry along with the promise of further changes to come....more

Dechert LLP

Starting a Hedge Fund in 2015

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Hedge funds are well into the transition from bastions of alternative investment to being accepted into the mainstream investment marketplace. It is now estimated that global hedge fund assets under management amount to in...more

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