News & Analysis as of

Investment Management Tax Liability

Strafford

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

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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

Nelson Mullins Riley & Scarborough LLP

Death, Taxes, and Crypto Reporting – The Three Things You Cannot Escape

The IRS released a draft of Form 1099-DA “Digital Asset Proceeds from Broker Transactions” in April which will require anyone defined as a “broker” to report certain information related to the sale of digital assets. The new...more

Cadwalader, Wickersham & Taft LLP

Location, Location, Location: New York’s Apportionment Rules for Investment Managers

New York State recently issued final corporate franchise tax regulations for sourcing income (the “Regulations”), including specific sourcing rules for service fees paid by passive investment customers (“PICs”) to investment...more

Cadwalader, Wickersham & Taft LLP

Limited Partner Exception Challenged by Hedge Fund Legend

An investment management firm founded and owned by legendary investor (and New York Mets owner) Steve Cohen on August 11 filed a petition in Tax Court contesting an IRS audit adjustment in the amount of $344,063,484 for tax...more

Dechert LLP

Learnings from Bluecrest – Investment Management LLPs and the Salaried Member Rules

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The First Tier Tax Tribunal on 29 June, 2022, issued its judgment in Bluecrest, the first case considering the application of the salaried member legislation to members of a hedge fund management LLP. The judgment will be of...more

Cadwalader, Wickersham & Taft LLP

UK Government Considering Expansion of Investment Transactions List to Include Crypto-Assets

The UK Government has announced a public consultation regarding the possible expansion of the UK’s investment manager exemption (“IME”) to encompass crypto-assets. The IME enables UK-based fund managers to provide...more

Dechert LLP

The UK Investment Manager Exemption and Cryptoassets – Consultation Document

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As part of wider efforts to make Britain a global hub for cryptoassets technology and investment, on 4 April 2022 the government publicly committed to consult on extending the scope of the UK Investment Manager Exemption (the...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

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

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

PRIVATE PLACEMENT LIFE INSURANCE WEBINAR

Discussion Points: a. Why financial advisors and life insurance agents should be selling PPLI now. b. An overview of the current lay of the land in PPLI. c. The important tax rules of PPLI. d. Planning examples using...more

McDermott Will & Emery

[Event] 2019 Private Client East Coast Forum - November 21st, New York, NY

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The unique needs of ultra-high net worth families, their family office representatives and other advisers are multidimensional and ever-evolving. Join us November 21 for McDermott Will & Emery’s Private Client East Coast...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

Foodman CPAs & Advisors

Los titulares de Moneda Virtual (MV) NECESITAN MANTENER REGISTROS

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La Sección 6001 del Código de Rentas Internas requiere que los Contribuyentes mantengan libros y registros adecuados. Mantener libros adecuados y buenos registros de la MV ayudará al Contribuyente a...more

Foodman CPAs & Advisors

Virtual Currency (VC) Holders NEED to KEEP RECORDS

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Internal Revenue Code Section 6001 requires Taxpayers to maintain adequate books and records. Keeping adequate VC books and good records will assist a Taxpayer to...more

Burr & Forman

South Carolina Property Tax for New and Expanding Manufacturers: The Fee-In-Lieu of Tax Versus the Special Source Revenue Credit

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South Carolina has some of the highest business property taxes in the Southeast. The state generally taxes land, buildings, machinery and equipment, and furniture and fixtures, but does not tax inventory, pollution control...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

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

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