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Tax Exemptions Investors

Proskauer Rose LLP

Proskauer’s Hedge Start: Key Tax Issues

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Different hedge fund investors have different tax concerns that must be taken into account when structuring a hedge fund and its portfolio investments. Hedge fund investors generally fall into three categories:...more

Fox Rothschild LLP

Tax Court’s Decision on YA Global Investments Has Implications for Offshore Entities

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The Tax Court’s decision in YA Global Investments LP v. Commissioner in November sends a warning to the offshore banking, finance and equity investment industries: an offshore entity is engaged in U.S. trade or business when...more

Morrison & Foerster LLP

Protecting Tax Assets – Considering an NOL Rights Plan - UPDATED

A corporation’s net operating losses (NOLs)are important assets that can be used to reduce future taxable income. But certain changes in a corporation’s ownership can significantly reduce the value of those NOLs....more

Rivkin Radler LLP

Sale of Partnership Interests . . . In the Ordinary Course of Business?

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What Is It? Where one stands on an issue of tax law may depend upon context and perspective, including the facts and circumstances one finds relevant, and whom one is counseling or representing. Tax advisers often find...more

Paul Hastings LLP

New Treasury Guidance on Sovereign Wealth Funds, Qualified Foreign Pension Funds, and REITS and RICs

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On December 28, 2022, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) on the treatment of qualified foreign pension funds (“QFPFs”) for purposes of the exemption from taxation for...more

King & Spalding

Checklist for Non-U.S. Fund Managers Making a Private Fund Offering in the U.S.

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The United States represents a large source of potential capitalthat non-U.S. fund managers often find impossible to ignore. To assist non-U.S. fund managers, we have prepared a checklist that sets out key considerations for...more

Troutman Pepper

FINRA Report Highlights New Topics and Emerging Risks for 2022

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On February 9, FINRA published its 2022 Report on FINRA’s Examination and Risk Management Program (2022 Report), an authoritative resource for member firms to evaluate and, where necessary, enhance their compliance programs...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for Trusts, Estates, and Retirement Accounts

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In this second blog post on the House Ways and Means Tax proposals, we address the proposed changes that will affect the taxation of trusts, estates, and retirement plans. As we discussed, on September 13, 2021, the...more

White & Case LLP

Top considerations –EMEA Tax trends impacting Private Equity Real Estate in 2021

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White & Case has advised a large number of high-profile international clients on cutting-edge, cross-border and domestic private equity real estate deals, providing valuable strategic tax insight to a broad range of investors...more

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

[Webinar] En mi Viejo San Juan - Puerto Rican Tax Incentives - October 6th, 2:00 pm - 3:00 pm EST

What we'll cover: - What is Act 22? - What is Act 20? - Requirements for U.S. Taxpayer - Planning Examples...more

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

One Note Samba

Using U.S. domestic trusts and private placement insurance products to invest in the U.S. ...more

Troutman Pepper

Investment Management Roundtable Discussion – Personal Estate Planning

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Gregory J. Nowak, a partner and practice leader for hedge funds in Pepper Hamilton’s Private Fund Services Practice Group, hosts a series of candid, interactive webinar discussions for West LegalEdcenter on what is going on...more

McDermott Will & Emery

Weekly IRS Roundup December 16 – 20, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

Akin Gump Strauss Hauer & Feld LLP

Upper Tribunal Overturns Decision on Tax Treatment of Management Fee Rebates

The Upper Tribunal (UT) has found that amounts paid by Hargreaves Lansdown (HL) (an investment platform service provider) to its customers, which represented rebates received from investment fund managers, were “annual...more

K&L Gates LLP

Hong Kong’s New Unified Tax Exemption for Onshore and Offshore Privately-Offered Funds

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Hong Kong’s Inland Revenue (Profits Tax Exemption for Funds) (Amendment) Bill 2018 (the “Bill”), which will take effect on 1 April 2019, represents a significant development for Hong Kong’s privately-offered funds industry by...more

Akin Gump Strauss Hauer & Feld LLP

Opportunity Zones: New Guidance Sheds Light on How Private Equity Industry Can Take Advantage

• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more

Bracewell LLP

Bracewell Tax Report - October 2018

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The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

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• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

Dechert LLP

Global Private Equity Newsletter - Winter/Spring 2018 Edition: Snapshot of Tax Act Changes for PE Funds and their Portfolio...

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President Trump signed into law tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”) on December 22, 2017. The Tax Act implemented the most far-reaching changes to the Internal Revenue Code (the...more

Proskauer - Proskauer For Good

Helping Non-Profits Navigate Tax and Labor Issues

Amanda Nussbaum, a partner in the Tax Department and a member of the Not-for-Profit Group at Proskauer, chairs a comprehensive seminar each fall for non-profits to discuss current developments and topics of interest related...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Healthcare Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Schwabe, Williamson & Wyatt PC

Summary of Tax Cuts and Jobs Act

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Hogan Lovells

A Changing World Creates Challenges and Opportunities for Sovereign Wealth Funds

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Can you describe your practice? Nikravesh: I devote a significant portion of my practice to working with sovereign wealth funds, public sector pension funds, social security funds, and other government investors,...more

Troutman Pepper

U.S.-India Newsletter - Vol. 2016, Issue 3

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Summer 2016 was a season of change. In Europe, we saw the "Brexit," with the United Kingdom voting to withdraw from the European Union. The June referendum sent shockwaves through the business and finance communities and...more

Troutman Pepper

Recent Changes to the India-Mauritius Tax Treaty: What Does This Mean for American Investors?

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The amendments may cause some uncertainty and anxiety for U.S. investors as they consider how these changes will impact business, income, profitability and the benefits or drawbacks of investing in India through Mauritius....more

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