News & Analysis as of

Investment Management Income Taxes

Skadden, Arps, Slate, Meagher & Flom LLP

The IRS Takes Aim at Basis Adjustments in Partnership Transactions

On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships: In new proposed regulations, the IRS identified several...more

Strafford

[Webinar] Tax Treatment of Leveraged Blockers Used by Foreign Investors: Recent IRS Guidance, Deal Structures, Tax Planning - June...

Strafford on

This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. assets utilizing leveraged blockers and other tax planning...more

Proskauer Rose LLP

UK Tax Round Up - March 2024

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Welcome to March’s edition of our UK Tax Round Up. This month has seen a number of interesting cases covering a range of issues, from the deductibility of costs against employment income to the place of effective management...more

Katten Muchin Rosenman LLP

PTC Me ASAP: Estate Planning with Private Trust Companies

More and more families are turning to private trust companies (PTCs) for their trusts and estates. Are they right for you?...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

Clark Hill PLC on

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

Dechert LLP

Luxembourg investment funds – Tax reporting obligations to be complied with by 31 May 2022

Dechert LLP on

Since 1 January 2021, certain corporate Luxembourg investment funds (i.e. Part II UCI, SIF and RAIF, as defined below) that hold real estate assets located in Luxembourg are subject to a special taxation, the so-called real...more

Freeman Law

Notable Tax Takeaways from President Biden’s Budget

Freeman Law on

On March 28, 2022, President Joe Biden released his FY 2023 Budget of the U.S. Government (the “Budget”). In a statement regarding the Budget, President Biden stated the following...more

Miller Nash LLP

Today in Tax: The Billionaire Minimum Income Tax and Cryptocurrency Tax Provisions in Biden’s 2023 Budget Proposal

Miller Nash LLP on

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. The Billionaire Minimum Income Tax in Biden’s 2023 Budget Proposal - Biden’s proposed “top-up” tax on wealthy individuals would ensure...more

Goodwin

New Developments on the VAT Exemption for Fund Management Services

Goodwin on

On 17 June 2021, the Court of Justice of the European Union (CJEU) rendered two decisions about the application of the VAT exemption for management services provided in article 135 (1) (g) of the EU VAT Directive and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Increased Funding Would Support IRS Drive To Audit More Partnerships and Wealthy Individuals

More — and more rigorous — IRS examinations are coming. The Biden administration is committed to closing the “tax gap” (the difference between taxes owed and taxes actually paid on time). Increased enforcement efforts are...more

Morgan Lewis

Sovereign Wealth Funds Update: Tax Aspects of Private Fund Investments: Selected US, EU, and UK Considerations in the Current...

Morgan Lewis on

Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more

Freeman Law

The Tax Court in Brief - January 2021

Freeman Law on

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of January 18 – January 22, 2021 - Adams Challenge (UK)...more

Skadden, Arps, Slate, Meagher & Flom LLP

Three Years, Two Pillars and One New Headache for Investment Funds

Fund sponsors, investment advisors and other financial market participants would be forgiven for not concerning themselves with tax initiatives originally targeted at the digital economy. However, with the latest technical...more

Gerald Nowotny - Law Office of Gerald R....

ROCK OF AGES - THE ARITHMATHEAN PENSION PLAN

Podcast episode #25 speaks to using the pooled income fund for non-deferred compensation planning. Provide key employees with a lifetime income of tax-free distributions. ...more

Gerald Nowotny - Law Office of Gerald R....

[Webinar] En mi Viejo San Juan - Puerto Rican Tax Incentives - October 6th, 2:00 pm - 3:00 pm EST

What we'll cover: - What is Act 22? - What is Act 20? - Requirements for U.S. Taxpayer - Planning Examples...more

Gerald Nowotny - Law Office of Gerald R....

THE ACCIDENTAL ENTREPRENEUR

Best way to structure your business to own multiple businesses in real estate and investment activities. Key benefits: Management and Control, Asset Protection, No FICA and Medicare Withholding and Ability to stagger a tax...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

Gerald Nowotny - Law Office of Gerald R....

Somewhere Over the Rainbow

Nowotny on Death and Taxes, episode 7, Somewhere Over the Rainbow, is about the use of private placement variable deferred annuities (PPVA) and trusts. ...more

Katten Muchin Rosenman LLP

IR35 — Incoming Changes Present New Compliance Burdens for Employers

Key Points - The off-payroll rules (IR35) aim to stop individuals from avoiding employee status for tax purposes (and thereby reducing the income tax and National Insurance Contributions (NICs) payable) by supplying their...more

Dechert LLP

Financial Services Quarterly Report - Third Quarter 2019: Developments in the UK Tax Treatment of Fee Rebates and Trail...

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UK investment managers paying fee rebates, loyalty bonuses or similar payments to UK investors and certain non-UK investors in collective investment schemes should note recent case law developments regarding the tax treatment...more

Akin Gump Strauss Hauer & Feld LLP

Upper Tribunal Overturns Decision on Tax Treatment of Management Fee Rebates

The Upper Tribunal (UT) has found that amounts paid by Hargreaves Lansdown (HL) (an investment platform service provider) to its customers, which represented rebates received from investment fund managers, were “annual...more

Bradley Arant Boult Cummings LLP

House Bill Makes Significant Changes to Retirement Plans - Employee Benefits Alert

Last week, the House of Representatives overwhelmingly passed the “Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019” (H.R. 1994) by a vote of 417-3. The bill makes numerous changes affecting...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding Tax and Reporting Action Items for Investment Funds and Asset Managers (Fall 2018)

• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more

Dechert LLP

Investment Funds Update Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Dechert LLP on

Irish Revenue Guidance on Section 110 - The Irish Revenue Commissioners (“Revenue”) issued a new Tax and Duty Manual (the “Tax Manual”) on 24 May 2018, setting out the position to deal with some of the uncertainties around...more

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