Carried Interest Tax Rates

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Your daily dose of financial news The Brief – 5.9.16

Friday’s jobs report underwhelmed, but it shouldn’t necessarily put off a June rate hike by the Fed, says the Journal, especially given the news that wages climbed last month – WSJ... Fair Game got downright monarchical...more

UK Taxation Update for Investment Managers

The shifting sands of the taxation landscape for investment managers continues apace. Just when you perceive an oasis of stability on the horizon, it is revealed to be a mirage by the announcement of yet further changes....more

New York State Bill Would Alter Taxation of Carried Interest

A bill recently introduced in the New York State Assembly would impose additional tax on carried interest. The taxation of carried interest has been widely discussed over the last decade, with a number of bills introduced...more

UK Budget 2016: Tax implications for the private equity sector

The private equity sector was a net loser from last week’s Budget, with the proposed restrictions on interest deductibility and a lifetime limit on employee shareholder schemes. The extension of entrepreneurs’ relief is...more

State, Local Taxes on Tribal Leases Vulnerable After California Court Order

Indian country may be close to another victory against state and local taxes. On Feb. 8, 2016, a California district court issued an order that signals it is likely to invalidate Riverside County's imposition of a possessory...more

IRS Releases FY 2017 Green Book Revenue Proposals

It’s that time of year when the President releases his annual wish list of tax revenue proposals, also known as the “Green Book”.  The 2017 Green Book includes many familiar items such as taxing Carried Interests as ordinary...more

Draft UK Income-based Carried Interest Legislation Published

Proposed new UK rules will tax carried interest in certain funds as income, with only specified funds entitled to capital gains treatment - The UK government published draft legislation on 9 December 2015 amending the...more

Financial Services Quarterly Report - Fourth Quarter 2015: Further Change to the UK Taxation of Carried Interest

The UK Government, as anticipated, issued draft legislation on 9 December designed to establish clear rules as to when carried interest can qualify for favourable capital gains tax treatment. The draft legislation follows a...more

Further Change to the UK Taxation of Carried Interest

The UK Government, as anticipated, issued draft legislation on 9 December designed to establish clear rules as to when carried interest can qualify for favourable capital gains tax treatment. The draft legislation follows a...more

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

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

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

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

Carried Interests OK Under Management Fee Waiver Regulations

Last week, I was at the ABA Tax Section meeting in Chicago. During one of the partnership panels, Clifford Warren, Special Counsel to the Associate Chief Counsel (Passthroughs and Special Industries) at the IRS, was posed...more

Tax Policy Update

First it was three years, now it’s three months. The Senate’s attempt to pass a multiyear highway bill ran off the road this week after House Republicans announced they will adjourn one day early for the month-long August...more

UK Summer Budget 2015: Osborne's 'Big Summer Budget' – the key measures impacting business

The first fully Conservative Budget for 18 years, following the end of the Coalition as a result of the May general election, was anticipated to be a 'Big Budget' but in truth it was a mixed bag: the game changers are the...more

Tax Measures in the UK 2015 Summer Budget

The new tax announcements are designed to improve productivity and correct imbalances in the tax system. On 8 July, UK Chancellor of the Exchequer George Osborne made a number of announcements relating to the tax system...more

Locke Lord QuickStudy: The Fate of Partnerships Under President Obama’s 2016 Proposed Budget

On Monday, February 2, President Obama formally released his 2016 budget proposal and, as expected, it contained numerous changes to the Internal Revenue Code. ...more

Why Am I Taxed Now on My Future Receipts: The Woes of a Profits Interest

Companies often grant stock options to incentivize employees and so that their interests are aligned with the future success of the company, and partnerships (and limited liability companies taxed as partnerships) are no...more

In the Money – Puerto Rico Me Encanta! Puerto Rican Hedge Funds

Overview - Every financial media outlet (including Bloomberg and the Wall Street Journal) in the last several weeks has run an article on the possibility of billionaire hedge fund manager becoming a Puerto Rican...more

Hard Hit Hedge Funds Flock to Invest in All Things Housing - and to Relocate Operations to Florida

Last year was not a good year for hedge funds, at least according to reports by experts like those at Goldman Sachs, where their own David Kostin is quoted in the media as having hedge funds underperforming at 88%. That's a...more

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