News & Analysis as of

Investment Management Internal Revenue Service

Employee Benefits Developments - August 2017

by Hodgson Russ LLP on

The Employee Benefits practice group is pleased to present the Benefits Developments Newsletter for the month of August, 2017. Affordable Care Act – “I’m not dead yet!” - The Patient Protection and Affordable Care Act...more

Investment Management Update

by Ballard Spahr LLP on

SEC Issues Guidance on Mutual Fund Fee Structure - The Securities and Exchange Commission’s (SEC) Division of Investment Management recently issued a guidance update addressing disclosure issues and certain procedural...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

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

MoFo Tax Talk - Volume 8, No. 3

by Morrison & Foerster LLP on

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

IRS Encourages Private Foundations to Consider Charitable Purposes in Investing Its Assets

As we previously reported, the IRS has updated its guidance with helpful examples concerning program-related investments for private foundations. In its recently issued Notice 2015-62, the IRS provides further assurance that...more

The Time to Transfer Entity Interests Is Now - Trust and Estates Update Vol. 2015, Issue 1

by Pepper Hamilton LLP on

Upcoming IRS regulations may significantly limit and reduce planning opportunities to transfer minority interests in closely held entities to family members and increase the transfer tax cost associated with moving such...more

IRS Issues Proposed Regulations Addressing “Fee Waiver” Arrangements

by Morgan Lewis on

The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more

IRS Determination Letter Program for Qualified Retirement Plans to Be Significantly Curtailed

by McGuireWoods LLP on

In Announcement 2015-19 (Announcement), the Internal Revenue Service (IRS) has indicated that it is eliminating the staggered five-year determination letter (DL) remedial amendment cycles for individually designed...more

The ERISA Litigation Newsletter - June 2015

by Proskauer Rose LLP on

Editor's Overview - In this month's newsletter, Anthony Cacace analyzes the heavily anticipated Supreme Court ruling in Tibble v. Edison Intl., 135 S. Ct. 1823 (2015), where the Court held that ERISA's fiduciary duty of...more

IRS: Investment Fund Managers are Subject to Self-Employment Tax

by Jackson Walker on

The Office of Chief Counsel of the Internal Revenue Service (the "IRS") recently issued internal guidance in the form of a Chief Counsel Advice (the "CCA") indicating that the IRS has taken the position that the "limited...more

IRS Considers Whether Management Fees of an LLC Are Subject to Self-Employment Tax

A recent response by the Internal Revenue Service Chief Counsel (CCA) to an inquiry from one of its field office agents addressed the question of whether management fees earned by an investment manager organized as a limited...more

Thomson Reuters Session 2: Investment Management, Hedge Funds and Registered Mutual Funds: What's Happening Now?

by Pepper Hamilton LLP on

Pepper partner Gregory J. Nowak has regularly hosted a roundtable in Pepper’s New York office for private funds and their managers to discuss issues in the investment management world. He has recently started to give a...more

Financial Services Tax – UK Update from Dechert’s Tax Group - February 2013: FATCA Update – No Duplicate Reporting for Investment...

by Dechert LLP on

Following the execution of an inter-governmental agreement (or “IGA”) with the United States in September 2012 and a consultation exercise which closed in late 2012, HM Revenue & Customs (“HMRC”) recently published draft...more

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