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Private Equity Tax Planning

Whiteford

To Roll or Not to Roll: Equity Roll Issues in Private Company M&A Deals

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This article is the first in a series on common issues of critical importance to sellers in private company M&A- An equity roll is an agreement between a Buyer and a Seller in an M&A deal where the Seller (typically a...more

Mayer Brown

Subscription Credit Facilities: Understanding Shared Blockers

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EXECUTIVE SUMMARY - Private equity structures often use “blockers” to achieve certain tax benefits. In this Legal Update, we explain what blockers are, how they may be used in a subscription credit facility, and what...more

Orrick, Herrington & Sutcliffe LLP

Deducting Success Fees in M&A Sell-Side Transactions: Guidance for Private Equity Portfolio Companies

In a typical sale of a private equity portfolio company, sell-side success fees payable to bankers and financial advisors represent one of the most significant transaction costs. Although most types of success fees are...more

Gray Reed

The Basis Matrix: Navigating the Interplay of Sections 743(b) and 734(b)

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Real estate funds and family offices are two types of investors that often (i) purchase equity interests in partnerships and (ii) make in-kind asset distributions for tax planning purposes. Well advised real estate and family...more

Troutman Pepper

Rolling Over and Section 704(c); What’s the Big Deal? — Part 4: The Remedial Method

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In our continuing series on Section 704(c) of the Internal Revenue Code (the Code) we discuss the application of the remedial method to correct for distortions caused by the ceiling rule. As previously discussed, when the tax...more

Troutman Pepper

Rolling Over and Section 704(c); What's the Big Deal? — Part 3: The Traditional Method With Curative Allocations

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Continuing with our series on the implications of the application of Section 704(c), the below discussion addresses the use of the traditional method with curative allocations. In Part 1 [insert link] we gave a broad overview...more

McDermott Will & Emery

[Event] Private Equity Boot Camp 2023 - November 9th, Munich, Germany

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We cordially invite you to our Private Equity Boot Camp in Munich this year. Experienced speakers from our Firm will train you and your colleagues during a workshop and provide legal and tax basics for the successful...more

Troutman Pepper

Rolling Over and Section 704(c); What's the Big Deal? — Part 2: The Traditional Method

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In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner. As...more

McDermott Will & Emery

[Event] Private Equity Bootcamp 2023 - June 22nd, Frankfurt, Germany

We cordially invite you to our Private Equity Bootcamps in Frankfurt and Munich this year. Experienced speakers from our firm will train you and your colleagues during a workshop and provide legal and tax basics for the...more

McDermott Will & Emery

[Event] Private Equity Bootcamp 2023 - November 9th, Munich, Germany

We cordially invite you to our Private Equity Bootcamps in Frankfurt and Munich this year. Experienced speakers from our firm will train you and your colleagues during a workshop and provide legal and tax basics for the...more

Alston & Bird

Tax Distributions

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Our Federal Tax Group discusses a common but critical partnership operating agreement provision that ensures partners won’t be paying taxes out of their own pockets....more

Williams Mullen

[Event] Hampton Roads Spring Tax Forum - May 17th, Norfolk, VA

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Join our seasoned tax and estate planning attorneys on Wednesday, May 17th in Norfolk for the Williams Mullen Spring Tax Forum. Breakfast will be provided. This program will dig into complex private equity structures, how...more

Freeman Law

Hedge Funds 101: An Introduction to Tax Issues

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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

Bilzin Sumberg

Tax Planning Considerations for Foreign Clients Making U.S. Private Equity Investments

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The United States is no stranger to capital from foreign investors. Perhaps in South Florida especially, this is no more evident than in the real estate market, particularly when it comes to investors from Latin America. Over...more

Proskauer Rose LLP

UK Tax Round Up - February 2021

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UK Case Law Developments - EIS relief not available for shares carrying preferential rights - The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more

Proskauer Rose LLP

UK Tax Round Up - December 2020

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COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more

Proskauer - Tax Talks

High Court decision highlights importance of ensuring claims notices include required information

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In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers’ argument that a notice of a tax claim under a tax covenant served on them by the buyer was invalid because it did not...more

Troutman Pepper

The Reintroduction of Net Operating Loss - A Pepper Hamilton and Financial Executives Alliance Webinar

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Recent law changes can provide portfolio company liquidity and/or require reconsideration of 2018–2020 deals. During this webinar, Steven D. Bortnick and Todd B. Reinstein, partners in the Tax and Estates Practice Group of...more

Williams Mullen

[Webinar] M&A Webinar Series: Tax-Free Rollovers in Private Equity Transactions, hosted by Williams Mullen - June 23rd, 11:00 am -...

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Do you often find yourself amid transactions that require a decision to sell a business to a private equity or other strategic buyer who are offering different consideration packages? Are you aware of the creative tax...more

Proskauer Rose LLP

UK Tax Round Up - February 2020

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UK General Tax Developments - HMRC updates to the private sector IR35 rules - On 7 February 2020, HMRC confirmed that the new private sector IR35 rules will only apply to payments made for services provided on or...more

Proskauer Rose LLP

UK Tax Round Up - October 2019

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UK Case Law Developments - Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation - In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more

Proskauer Rose LLP

UK Tax Round Up - September 2019

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Case Law Developments - Place of supply for VAT purposes - The recent case of American Express Services Europe Limited (AESEL) v HMRC is a useful reminder of the well-established two-stage approach to determining the...more

Dechert LLP

Global Private Equity Newsletter - Winter 2019 Edition: U.S. Carve-Out Transactions: A Fertile Ground for Private Equity Firms

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Driven by the influence of shareholders, activists and competitive market forces, public companies are demonstrating renewed focus on their core businesses. Reductions in the U.S. corporate tax rate from 35% to 21% have...more

Williams Mullen

IRS Gets “Bageled” in Tax Court Over Family Office Expenses

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A recent case, Lender Management LLC v. Commissioner of Internal Revenue, T.C. Memo. 2017-246, has created a window of opportunity for family offices to restructure their affairs and potentially deduct certain family office...more

Holland & Knight LLP

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

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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

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