News & Analysis as of

Internal Revenue Service Investment Funds

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
DLA Piper

Withholding Requirements for Transfers of Venture Capital Fund Interests by Non-US Limited Partners

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The secondary market for limited partner interests in venture capital funds has witnessed robust growth in recent years as an increasing number of existing venture fund investors seek an early exit from their positions for...more

Seward & Kissel LLP

New FATCA Agreement with Switzerland

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The United States and Switzerland jointly announced the conversion of the intergovernmental agreement (“IGA”) from a “Model 2” to “Model 1” agreement. The new IGA will come into effect January 1, 2027, allowing time for...more

McDermott Will & Emery

The Domestic Content Bonus Credit’s Promising New Safe Harbor

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On May 16, 2024, the Internal Revenue Service (IRS) published Notice 2024-41 (Notice), which modifies Notice 2023-38 (Prior Notice) by providing a new elective safe harbor (Safe Harbor) that will allow taxpayers to use...more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

Investment Fund Manager Update on Self-Employment Limited Partner Exception: Tax Court Holds that Limited Partners May Be Subject...

On November 28, 2023, the Tax Court held that limited partners in state law limited partnerships cannot automatically rely on Section 1402(a)(13) of the Self-Employment Contributions Act (“SECA”) to exclude their distributive...more

Seward & Kissel LLP

For Fund Managers, Tax Court Ruling Sets Limited Partners Back “As Such”

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Memorandum to our Investment Management Clients and Friends - The United States Tax Court recently issued a ruling (the “Ruling”) pertaining to the possible exclusion of a limited partner’s distributive share of income...more

Morgan Lewis

Taxpayer Victory in US Tax Court Highlights Need for Properly Structuring Partnership Profits Interests

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A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a...more

Polsinelli

Appraiser Pleads Guilty to Fraud in Syndicated Conservation Easement Case

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Polsinelli’s Government Investigations and Tax attorneys continue to follow the well-known Fisher case, the Department of Justice’s ("DOJ") first criminal indictment related to syndicated conservation easements. Walter...more

Akin Gump Strauss Hauer & Feld LLP

IRS Takes View That FIRPTA Exemption for Publicly Traded Stock Must Be Tested at Partnership Level

Key Points Internal IRS correspondence in the form of a recent Chief Counsel Memorandum concludes that funds structured as partnerships (e.g., master funds in a standard master-feeder structure) must determine the...more

Bilzin Sumberg

Proposed Regulations May Affect Taxation of Foreign Investors in REITs

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On December 29, 2022 the IRS and the Treasury Department issued a notice of proposed rulemaking (REG-100442-22) (the “Proposed Regulations”) that, among other things, affects the determination when Real Estate Investment...more

Verrill

DOL Proposes Amendments to QPAM Exemption

Verrill on

On July 27, 2022, the Department of Labor (DOL) proposed a set of amendments to Prohibited Transaction Class Exemption 84-14, the so-called “QPAM Exemption,” which permits an investment fund holding assets of ERISA plans and...more

Lowndes

Bipartisan Bill Proposes Changes to Opportunity Zone Benefits

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If you acquired or built a senior living facility that is located in an opportunity zone, or are considering doing so, a recent bipartisan bill introduced in Congress proposes making changes to the opportunity zone rules. ...more

Sullivan & Worcester

Proposed Bipartisan Amendments to the Opportunity Zone Statute Could Have a Significant Effect on Current and Potential Investors

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Late last week, a bipartisan group of U.S. Senators and U.S. Representatives introduced an expansive bicameral bill, titled the Opportunity Zones Transparency, Extension, and Improvement Act (the “OZ Bill”). This proposed...more

Obermayer Rebmann Maxwell & Hippel LLP

Call to Increase Transparency Of Opportunity Zone Program

From the date of its inception, the Opportunity Zone Program has been criticized for its lack of transparency and reporting requirements. The original version of the law included reporting requirements, but some of those...more

McDermott Will & Emery

The Nonqualified Financial Property Limitation

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Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

McDermott Will & Emery

The 90 Percent Test

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

McDermott Will & Emery

How to Invest in a QOF

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

McDermott Will & Emery

The Benefits of Investing in a QOF

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Williams Mullen

Ding Dong, the OZ Ground Lease (May Be) Dead!

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As a practitioner who regularly advises clients on qualified opportunity zone (OZ) matters, I have spent the bulk of the past three years discussing ground lease structures. Developer clients initially cringed at the notion,...more

Butler Snow LLP

Combining the Energy Credit with New Markets Tax Credits

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Section 48 of the Internal Revenue Code of 1986 provides for a credit equal to a percentage of the cost of new equipment for the generation of renewable energy, including solar energy used to produce electricity or to heat or...more

Winstead PC

Additional Short-Term Relief Granted for Qualified Opportunity Funds and Investments

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As a result of the continuing COVID-19 impact on qualified opportunity funds (“QOFs”) and prospective investors therein, the IRS recently issued Notice 2021-10 (the “Notice”) in order to grant additional relief to QOF and...more

Stinson LLP

IRS Extends Relief for Qualified Opportunity Funds

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On January 19, 2021, the IRS issued Notice 2021-10, further extending relief for qualified opportunity funds (QOF) and their investors due to the COVID-19 pandemic. The IRS had provided relief last year in Notice 2020-39, and...more

Latham & Watkins LLP

Final Carried Interest Regulations: Key Takeaways for Private Fund Sponsors

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While the final regulations simplify key exceptions and contain favorable changes, ambiguity continues for investment fund managers. On January 7, 2021, the US Treasury Department and Internal Revenue Service (together,...more

Sullivan & Worcester

Internal Revenue Service Provides Additional COVID-19 Related Relief for Opportunity Zones Investors

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On January 19, 2021, the Internal Revenue Service (“IRS”) issued Notice 2021-10 (the “Notice”), which provides relief for Opportunity Fund investors from certain deadlines and testing requirements. The relief provided by the...more

Morgan Lewis

IRS Extends Previously Issued Relief to Qualified Opportunity Funds and Their Investors

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The Internal Revenue Service (IRS) issued Notice 2021-10 on January 19, which extends relief to Qualified Opportunity Funds (QOFs) and their investors as a response to continued challenges brought on by the COVID-19 pandemic....more

Allen Matkins

Extensions of COVID-19 Relief for Opportunity Zone Funds

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In IRS Notice 2021-10 (the New Notice), the IRS granted relief to Opportunity Zone Funds because of the COVID-19 pandemic. The New Notice generally extends the relief that had previously been granted pursuant to IRS Notice...more

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