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Internal Revenue Service Private 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.  
ArentFox Schiff

Self-Directed IRAs and the Prohibited Transaction Rules – Part 1

ArentFox Schiff on

Part 1: Permitted Investments and Compliance - The self-directed individual retirement account (IRA) is an increasingly popular option for an IRA account owner, especially those owners who have significant net worth and...more

Morgan Lewis

Inflation Reduction Act of 2022 Would Alter the Taxation of Carried Interest

Morgan Lewis on

US Senators Joe Manchin and Chuck Schumer announced on July 27 an agreement in principle on a legislative proposal, known as the Inflation Reduction Act of 2022, that includes a range of measures addressing consumer energy...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

Latham & Watkins LLP

Final Carried Interest Regulations: Key Takeaways for Private Fund Sponsors

Latham & Watkins LLP on

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

Morgan Lewis

IRS Issues Final Regulations on Carried Interests

Morgan Lewis on

The Internal Revenue Service and the US Department of the Treasury pre-released final regulations, T.D. 9945, under Section 1061 on January 7, providing guidance to the holders of certain carried interests. These rules are of...more

Stinson LLP

IRS Releases Carried Interest Proposed Regulations

Stinson LLP on

On July 31, the IRS issued proposed regulations under Section 1061 of the Internal Revenue Code further clarifying the tax treatment of carried interest and other "applicable partnership interests" (APIs)....more

Morgan Lewis

IRS Issues Proposed Regulations on Carried Interests

Morgan Lewis on

The Internal Revenue Service (IRS) and the US Treasury Department released proposed regulations (REG-107213-18) under Section 1061 on July 31 providing guidance to the holders of certain carried interests. These rules are of...more

Miles & Stockbridge P.C.

Social Impact Bond Success

Miles & Stockbridge P.C. on

Governments spend billions of dollars annually trying to address social problems. Most of these funds are not spent on prevention of such problems, and when they are spent on prevention, it can be challenging to find...more

Proskauer Rose LLP

Proposed Regulations Issued On Management Fee Waivers

Proskauer Rose LLP on

On July 22, 2015, the U.S. Department of the Treasury and U.S. Internal Revenue Service issued proposed Treasury Regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended, addressing management...more

Miller & Martin PLLC

SEC Eliminates Ban on General Solicitation in Private Offerings

Miller & Martin PLLC on

On July 10, 2013, the SEC took the following actions that are likely to have a significant impact on hedge funds, private investment funds and other companies that raise capital through private offerings of securities...more

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