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Investment Management Tax Deductions

Freeman Law

The Tax Court in Brief - January 2021

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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

Rosenberg Martin Greenberg LLP

Final Section 199A Regulations: Initial Takeaways on Clarification of Definition of "Specified Service Trade or Business"

Since the passage of the Tax Cuts and Jobs Act, business owners and tax practitioners alike have focused on the potential effect of Section 199A. Though it has been clear for some time that the 20% deduction afforded to...more

Troutman Pepper

Tax-Efficient Structuring Considerations for Family Office Management Expenses

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A recent case, Lender Management, LLC v. Commissioner, provides a potential roadmap for family offices on how to structure their operations for U.S. federal income tax purposes. ...more

Williams Mullen

IRS Gets “Bageled” in Tax Court Over Family Office Expenses

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A recent case, Lender Management LLC v. Commissioner of Internal Revenue, T.C. Memo. 2017-246, has created a window of opportunity for family offices to restructure their affairs and potentially deduct certain family office...more

A&O Shearman

Tax Court Rules Family Office Is Engaged in a Trade or Business

A&O Shearman on

On December 13, 2017, in Lender Management, LLC v. Commissioner, the U.S. Tax Court ruled that a family office, Lender Management, LLC (“Lender Management”), was “carrying on a trade or business” as an investment manager...more

K&L Gates LLP

Tax Reform and Investment Management: Initial Observations

K&L Gates LLP on

On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the “Act”). While the Act will impact many types of taxpayers, some of the more significant changes are relevant to private funds, investment advisers,...more

Cadwalader, Wickersham & Taft LLP

Effects of House Tax Reform Bill on Securitizations and Funds

On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”). The Bill, which is entitled the “Tax Cuts and Jobs Act,” includes significant changes to the...more

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

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

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

Proskauer Rose LLP

UK Summer Budget 2015 – Key Issues for Asset Managers and Non-UK Domiciled Individuals

Proskauer Rose LLP on

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

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