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Private Equity Carried Interest

Dechert LLP

Labour Party Manifesto: Key Tax Points for Investment Managers

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The Labour Party Manifesto for the election on 4 July 2024 has now been published. Our key tax takeaways from the manifesto for the asset management sector are as follows:.....more

Goodwin

Approaches Funds Take to Catch-Up Payments Vary by Asset Class

Goodwin on

For a majority of PE, VC, and debt funds, catch-ups are 100%, but they are likely to be less than 100% for real estate and infrastructure funds. In a previous article, we showed that hurdle rates set by private...more

Levenfeld Pearlstein, LLC

Inflation Reduction Act – Channeling The Terminator: I’LL BE BACK

Those of you who followed the drama around the oddly-named Inflation Reduction Act of 2022 will have seen the rise and fall of efforts to change tax laws regarding “carried interests.”...more

Freeman Law

Hedge Funds 101: An Introduction to Tax Issues

Freeman Law on

Hedge Funds and Taxes - Hedge funds provide a vehicle to pool private capital for investment in stocks, securities and financial derivatives. While hedge funds take on many different structures—including master-feeder,...more

Ballard Spahr LLP

Carried Interest – Proposed Regulations and the Impact on Private Equity

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Treasury and the IRS released proposed regulations under Section 1061 of the Internal Revenue Code (the Code) on July 31, 2020, that require certain taxpayers to satisfy a three-year holding period, rather than a one-year...more

Proskauer Rose LLP

Key Takeaways from the Proposed Regulations on Carried Interest

Proskauer Rose LLP on

On July 31, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) providing guidance on Section 1061 of the Code, as...more

Ballard Spahr LLP

Is Private Equity “Ready for Warren?

Ballard Spahr LLP on

Massachusetts Senator and presidential hopeful Elizabeth Warren released perhaps the most ambitious plan the country has ever seen with respect to regulation of the private equity and investment fund industry. She released...more

Katten Muchin Rosenman LLP

ILPA Principles 3.0: Focusing on Enhancing Transparency in Private Equity Funds and Alternative Investments

The Institutional Limited Partners Association (ILPA) recently published the third edition of the ILPA Principles (Principles 3.0). ILPA originally published the principles in 2009 to encourage discussion between general...more

K&L Gates LLP

Legislation Targets Carried Interest

K&L Gates LLP on

Sen. Tammy Baldwin (D-WI) and Rep. Bill Pascrell (D-NJ) recently reintroduced the “Carried Interest Fairness Act of 2019” (the “Act”). The sponsors claim that the Act would “provide for the proper tax treatment of personal...more

Vedder Price

Tax Reform: Impact on Private Equity and M&A

Vedder Price on

On December 22, 2017, new tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Act”) was signed into law. The Act represents a major overhaul of the U.S. federal tax system and includes many new provisions,...more

Sheppard Mullin Richter & Hampton LLP

The Effects of Tax Reform on Private Equity

On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (TCJA), the most extensive overhaul of the United States tax regime in over thirty years. The new tax law will have a significant impact upon...more

Holland & Knight LLP

Private Equity and Other Carried Interest Funds – Federal Tax Policy Tip Sheet: Issue 4

Holland & Knight LLP on

The House of Representatives on Nov. 16, 2017, voted on and passed their tax reform bill, along party lines (227-205). Passage was expected in the House, where the GOP hold a significant enough majority needed to move the...more

Holland & Knight LLP

Private Equity and Other Carried Interest Funds – Federal Tax Policy Tip Sheet: Issue 3

Holland & Knight LLP on

The Top Line - The House Ways and Means Committee completed its marathon "markup" of the tax-reform bill this week, paving the way for a floor vote on the measure as soon as next week....more

Holland & Knight LLP

Private Equity and Other Carried Interest Funds – Federal Tax Policy Tip Sheet: Issue 2

Holland & Knight LLP on

House GOP leaders on Thursday, Nov. 2, released their anticipated tax-reform proposal. Entitled the "Tax Cuts and Jobs Act," the House Bill includes several proposed changes to the corporate and individual tax system....more

Hogan Lovells

Italy passes new rules for carried interest

Hogan Lovells on

The Italian Government has at last put an end to the controversy around the characterisation of 'carried interest' for tax treatment purposes. By Law Decree no. 50 of 24 April 2017, which is to be brought into law by 23 June...more

Dechert LLP

Global Private Equity Newsletter - Summer 2016 Edition: Estate Planning Opportunities with Interests in Private Equity Funds

Dechert LLP on

Typically, the sponsors of private equity funds are focused on the fundraising process and the initial launch of the fund, and little attention is devoted to the estate planning opportunities that may be best exploited at the...more

Skadden, Arps, Slate, Meagher & Flom LLP

"No Gains, Just Pain: Increasingly Uncomfortable Taxation Environment for Private Equity Executives’ Compensation"

Arguing that their compensation should count as capital gains — since it derives from the appreciation in value of portfolio companies — private equity executives in Europe generally have been taxed under the more favorable...more

Dechert LLP

Global Private Equity Newsletter - Fall 2015 Edition: The Summer Budget – Changes to the UK Tax Treatment of Carried Interest

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The Chancellor of the Exchequer’s recent Summer Budget and the related legislation introduced a series of unexpected tax changes along with the promise of further changes to come. Shortly after the Summer Budget was issued...more

Faegre Drinker Biddle & Reath LLP

IRS Issues Proposed Regulations Addressing Fee Waivers

On July 22, 2015, the U.S. Department of the Treasury issued proposed regulations addressing the tax treatment of certain private equity management fee waivers. These new rules could result in many common management fee...more

Katten Muchin Rosenman LLP

Summer Budget 2015––Carried Interest: Abolition of Base Cost Shift

On July 8, the Right Honourable George Osborne MP, Chancellor of the Exchequer, introduced measures in his Summer Budget to abolish what is commonly known as the “base cost shift” as applied to sums received by individuals...more

Dechert LLP

The UK Summer Budget - Private Equity and Investment Management

Dechert LLP on

The Chancellor of the Exchequer’s Summer Budget on 8th July introduced a series of unexpected tax changes affecting the private equity and investment management industry along with the promise of further changes to come....more

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

Can We Talk? Providing Hedge Fund Managers with the Deferral of Carried Interest until Eternity

Overview - The recent passing of Joan Rivers not only requires us to pay tribute to one of the great comedic minds of the last forty-fifty years, but serves as a testimony to professional passion, perseverance and hard...more

Brownstein Hyatt Farber Schreck

Recent Decision of the U.S. Court of Appeals for the First Circuit May Have Significant Implications for Private Equity Funds

In late July of this year, the U.S. Court of Appeals for the First Circuit reversed a Massachusetts District Court, and in a decision of first impression, held that one of Sun Capital Partner’s private equity funds was liable...more

BakerHostetler

Planning for Carried Interests & Avoiding Section 2701

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Alternative investments in private equity and hedge funds have gained in popularity over the last two decades and have become a regular allocation of many investment portfolios....more

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