News & Analysis as of

Investment Partnerships

Applying the Look-Through Rules in Determining 'Investment Partnership' Status Under Section 721(b) - Tax Update Volume 2017,...

by Pepper Hamilton LLP on

Careful Evaluation and Planning Should Be Undertaken When the Partnership Is Formed and When Assets Are Contributed to Evaluate the Potential Impact of Section 721(b). Many taxpayers choose partnership structures...more

Financial Services Quarterly Report - Fourth Quarter 2016: The Impact of New U.S. Partnership Audit Rules on Investment...

by Dechert LLP on

The U.S. Bipartisan Budget Act of 2015 amended the provisions of the U.S. Internal Revenue Code of 1986, as amended (Code), governing partnership audit proceedings. The new provisions are designed to simplify the ability of...more

The Unwind: ‘I Don’t Want It’

In the inaugural column of ‘‘Power and Taxes,’’ we discussed the tensions surrounding the requirement that an investor be an owner when a project is placed in service in order to qualify for the investment tax credit under...more

Virtus Investment Partners Asks the Court to Certify for Interlocutory Appeal Its Decision on Loss Causation Concerning Mutual...

Although this blog is focused typically on opportunities for institutional investors to recover losses as class members or plaintiffs, we think this decision in Youngers v. Virtus Investment Partners, Inc., may also be of...more

Tax Treatment of “Bad Boy Guarantees” Challenged by Recent IRS Memorandum

by Morrison & Foerster LLP on

I. OVERVIEW - A recently released legal memorandum by the Internal Revenue Service (IRS) Office of Chief Counsel, CCA 201606027 (the “Memorandum”), concluded that a so-called “bad boy guarantee” provided by a sponsor of...more

German Fund Taxation: A Roundup of Recent Developments

by Dechert LLP on

Germany’s fund taxation regime continues to evolve as the country further refines and reforms domestic tax laws that were subject to significant changes towards the end of 2013 – when Germany introduced new domestic tax rules...more

Investment Funds Update - Europe: Key legal and regulatory updates for the funds industry from the primary European asset...

by Dechert LLP on

Federal Ministry of Finance Guidance on Tax for Closed-Ended AIFs - The Federal Ministry of Finance has issued guidance on 12 February 2015 that broadens the favorable tax regime for investment partnerships applicable to...more

Fourth Circuit Affirms Dismissal of Securities Claim Alleging Accounting Fraud

by Smith Anderson on

If you thought it was difficult to make a federal securities fraud claim stick in the Fourth Circuit, the court has now raised the bar even higher. The Fourth Circuit recently affirmed a trial court’s dismissal of securities...more

New Tax Benefits for Investment Projects in the Russian Far East

by K&L Gates LLP on

Companies that carry out qualifying investment projects in the Russian Far East enjoy tax benefits under a new Federal Law “On the Introduction of Amendments to Parts One and Two of the Tax Code of the Russian Federation...more

German Investment Tax Act for Alternative Investment Funds

by Dechert LLP on

The German Ministry of Finance published on 4 December 2012 a draft bill amending the German Investment Tax Act, which is the special German tax regime for German investors investing in German and foreign investment funds....more

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