4 Key Takeaways | Mid-Year Tax Update
THE WAY WE WERE
Investment Management Update – Exit Strategies
Podcast: Introduction to Credit Funds: Basics on How Credit Funds and Private Equity Funds Differ
Episode 26: Talking Tax Reform and Executive Comp
Jeffrey DeBoer on the intersection of Washington and commercial real estate
The Labour Party Manifesto for the election on 4 July 2024 has now been published. Our key tax takeaways from the manifesto for the asset management sector are as follows:.....more
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
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
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
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
Hedge Funds and Taxes - Hedge funds provide a vehicle to pool private capital for investment in stocks, securities and financial derivatives. While hedge funds take on many different structures—including master-feeder,...more
In the first REIT Series presentation of 2021, V&E tax attorneys will discuss the final carried interest regulations and their impact on REIT LTIP unit holders and real estate fund sponsors and operating partners....more
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
We at The Capital Commitment blog have previously discussed several steps for fund managers and others to weather the storm brought by COVID-19. One of those steps is assessing the likelihood of a carried interest return...more
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
Gregory J. Nowak, a partner and practice leader for hedge funds in Pepper Hamilton’s Funds Services Practice Group, hosts a monthly webinar series for West LegalEdcenter. This month, Mr. Nowak, is joined by Richard Juliano,...more
The federal tax reform legislation that became law on December 22, 2017 contains a provision that will impose a new limitation on investment managers with respect to capital gains derived through carried interests in...more
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
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
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
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
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
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
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
The world of private investment funds has been evolving to address the specific goals and expectations of investors, including pension plan sponsors and other investors with specific regulatory and economic needs. As a...more
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
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
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