News & Analysis as of

Carried Interest

Prediction Markets' Forecast on Tax Changes

by Slim Ventures LLC on

Prediction markets accuracy rates average 74%[1], and are more often more accurate than expert or public opinion surveys. With that in mind, we thought we would give you the prediction markets’ take on the likelihood of...more

Italy Addresses "Carried Interest" Tax Treatment

by Jones Day on

The Italian government has enacted Law Decree no. 50 ("Decree 50"), providing a set of new tax measures aimed at, among other things, attracting investments in Italy. Decree 50 was finally approved by the Italian Parliament...more

Tackling Tax Reform – Part IV: What Can We Expect To See

by Garvey Schubert Barer on

On April 11, 2017, we discussed what constitutes Tax Reform. On April 24, 2017, we explored the process by which Tax Reform will likely be created by lawmakers. In our May 3, 2017 blog post, we focused on the likely timing...more

Italy passes new rules for carried interest

by Hogan Lovells on

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

Sweden Rules on Taxation of Carried Interest in Private Equity Structures

by DLA Piper on

Sweden's Administrative Court of Appeal (SACA) has issued a decision on the taxation of carried interest in a number of private equity structures. In most of these structures, carried interest was taxable at least partly as...more

Finnish Supreme Administrative Court ruled on carried interest in private equity structures

by DLA Piper on

On 16 March 2017, the Supreme Administrative Court (SAC) of Finland issued a ruling on the tax treatment of carried interest in a private equity structure. The SAC ruled that carried interest is taxed as income of the limited...more

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

by Proskauer - Tax Talks on

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

IRS Begins to Target Management Fee Waivers on Audit

According to a recent BNA news report, the Internal Revenue Service (IRS) has proposed adjustments and penalties to a private fund manager related to its use of management fee waivers and transaction fee offsets. Based on the...more

Trump Administrations Agenda affects Wealth Management

There’s little doubt that President Trump will carry through on the many promises that he made during the campaign that affect individuals, investors and advisors in the Wealth Management Industry. Corporations, too, were...more

Examining the Impact of the 2016 US Elections on Executive Compensation

by Latham & Watkins LLP on

Will it soon be time to chart a new course in executive compensation? As a result of the November 8, 2016 election, Republicans will control the Presidency, the Senate and the House of Representatives beginning on...more

Energy Private Equity and the Looming Specter of Clawbacks

In recent months, managers of private equity funds in the energy sector have been facing a scenario they likely never imagined: having to return millions of dollars of their “carried interest” earnings back to investors....more

Looking over the edge of the Cliff - The Use of Pooled Income Funds to Reduce the Taxation of Offshore Repatriated Carried...

by Gerald Nowotny on

The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more

What Is Carried Interest?

During the second presidential debate, one of the few things that both candidates agreed on was doing away with carried interest as part of their proposed tax changes. But they never explained what it is. So what was is...more

Global Private Equity Newsletter - Summer 2016 Edition: Estate Planning Opportunities with Interests in Private Equity Funds

by Dechert LLP on

Typically, the sponsors of private equity funds are focused on the fundraising process and the initial launch of the fund, and little attention is devoted to the estate planning opportunities that may be best exploited at the...more

Structuring Equity Interests for Independent Sponsors

In a traditional private equity fund, the fund managers will raise money from investors to establish a pool of capital the fund can then use to invest in a number of portfolio companies. A big benefit of a fund is that the...more

Carried Interest: Belgian Ruling Commission Confirms Application Of Stock Option Law

by Allen & Overy LLP on

The Belgian Stock Option Law sets out the tax treatment of stock options, thereby eliminating the uncertainty as to the taxable value of the stock options. In the past, the Belgian Ruling Commission has been reluctant to...more

UK Taxation Update for Investment Managers

by Dechert LLP on

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

Tax Announcements in the UK’s Budget 2016

by Proskauer - Tax Talks on

The UK’s 2016 budget was announced on Wednesday 16 March 2016. Although we are waiting for detailed legislation for most of the tax-related announcements, below is a brief summary of some tax points which have caught our...more

Looking Over the Edge of the Cliff– The Use of Pooled Income Funds for the Repatriation of Offshore Carried Interest

by Gerald Nowotny on

The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more

Obama's Budget Proposals Expand Application of Net Investment Income Tax and Address Carried Interest

by Proskauer Rose LLP on

On February 9th, President Obama released his Budget Proposals for 2017 (the "Budget Proposals"). The Budget Proposals include the following proposals that may affect private investment fund managers...more

Draft UK Income-based Carried Interest Legislation Published

by Latham & Watkins LLP on

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

"No Gains, Just Pain: Increasingly Uncomfortable Taxation Environment for Private Equity Executives’ Compensation"

Arguing that their compensation should count as capital gains — since it derives from the appreciation in value of portfolio companies — private equity executives in Europe generally have been taxed under the more favorable...more

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

by Dechert LLP on

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

by Dechert LLP on

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

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