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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

Dechert LLP

Another Stab at Carried Interests Under the Inflation Reduction Act of 2022

Dechert LLP on

On July 27, 2022, Senator Joe Manchin III (D-W.Va.) and Majority Leader Charles E. Schumer (D-N.Y.) introduced legislation entitled the “Inflation Reduction Act of 2022” (the “Reconciliation Bill”). The Reconciliation Bill is...more

McDermott Will & Emery

Inflation Reduction Act & Long-Term Capital Gain for Carried Interest

OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Gray Reed

Carried Interest Taxation: Update on Final Regulations and Potential Legislative Changes

Gray Reed on

In January 2021, the U.S. Department of Treasury and the Internal Revenue Service  released final regulations (the Final Regulations) under Section 1061 of the Internal Revenue Code of 1986, as amended (the Code).  Code...more

Cadwalader, Wickersham & Taft LLP

Wyden’s Carried Interests Bill

On August 5, 2021, U.S. Senate Finance Committee Chair Ron Wyden (D-Ore.) and Senator Sheldon Whitehouse (D-R.I.) introduced legislation that, if enacted, would tax carried interest recipients annually at ordinary interest...more

Burr & Forman

Summary of Proposed 2021 Federal Tax Law Changes

Burr & Forman on

President Biden has proposed major changes to the Federal tax laws, some of which are sought to be effective earlier in 2021 (i.e., we are already operating under these changes, if they later become adopted), as compared to...more

Polsinelli

A Summary of Potential Tax Increases That Would Occur Under the Proposed American Families Plan

Polsinelli on

On April 28, 2021, the White House issued a fact sheet which set forth some additional details on the tax increase proposals contained in President Biden’s “American Families Plan.” ...more

Goulston & Storrs PC

Wealth Planning and the New Administration: Potential Individual Income & Transfer Tax Changes

Goulston & Storrs PC on

On April 28, 2021, in an address to a Joint Session of Congress and a Fact Sheet published by the White House, President Biden introduced the “American Families Plan,” the President’s plan for spending and a series of tax...more

Cadwalader, Wickersham & Taft LLP

A Look at the Tax Provisions in Biden’s Infrastructure Plan

The American Jobs Plan is a $2 trillion plan to repair and revitalize America’s infrastructure. The plan includes: $115 billion to repair bridges, highways, roads and other transit systems...more

Morgan Lewis

Tax Reform in the American Families Plan

Morgan Lewis on

The Biden-Harris administration on April 28 introduced the American Families Plan (AFP), a $1.8 trillion legislative framework including provisions to “grow the middle class, expand the benefits of economic growth to all...more

Cadwalader, Wickersham & Taft LLP

Biden Tax Proposals to Pay for the American Families Plan

On April 28, 2021, President Biden announced the American Families Plan, a $1.8 trillion proposal that would fund a number of education and childcare projects....more

Lowndes

Biden Proposes Tax Hike on Businesses and High-Income Individuals

Lowndes on

Over the last month, President Biden has discussed various tax proposals that will increase income taxes on businesses and high-income individuals. In the last week, we have learned more about what some of those proposals...more

Morgan Lewis

Tax Reform on the Horizon: Current Developments and Updates

Morgan Lewis on

With the recent passage of the COVID-19 stimulus package, President Joseph R. Biden, his administration, and Congress have turned their attention to long-term economic recovery, deficit reduction, and tax reform. ...more

Goulston & Storrs PC

Carried Interest & Deductibility: What is the Best Option for Your Family Office Structure?

Goulston & Storrs PC on

Should a family office asset manager receive a carried interest from the family investment vehicles it manages? If yes, how does the carried interest align with the intergenerational planning of the family office?...more

Cadwalader, Wickersham & Taft LLP

Carried Interests in the Crosshairs (Again)

Democrats have proposed a bill to tax carried interests at ordinary income rates. Under current law, fund managers generally recognize income or gain in respect of their carried interests only when the fund sells assets that...more

Goodwin

Highlights From The Final Carried Interest Regulations

Goodwin on

On January 7, 2021, the U.S. Treasury Department and the Internal Revenue Service released final regulations under Section 1061 of the Internal Revenue Code of 1986, as amended (“the Code”). The Final Regulations address the...more

Cozen O'Connor

Proposed Regulations Provide Guidance for the Carried Interest Rules — Six Important Takeaways

Cozen O'Connor on

On Friday, July 31, 2020, the IRS released a Notice of Proposed Rulemaking (Proposed Regulations) setting forth guidance under Code Sec. 1061, the so-called “carried interest” rules. The carried interest rules under Code Sec....more

Proskauer - Tax Talks

State Tax Law Updates

Proskauer - Tax Talks on

A number of states have recently proposed or passed new laws related to state-level taxation, some of which are taxpayer-friendly and some of which are expected to impose additional tax burdens on taxpayers. They vary in...more

Dechert LLP

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

Dechert LLP on

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

Lowndes

Tax Cut and Jobs Act Limits Benefit of Carried Interest

Lowndes on

After many years of being the target of Congress and the IRS, the Tax Cut and Jobs Act finally succeeded in limiting the beneficial tax treatment of carried interests, at least for some taxpayers. This change will be of...more

Orrick, Herrington & Sutcliffe LLP

Private Equity Fund Taxation Post-Tax Reform: What Really Changed?

Congress has passed the tax reform bill, known as the “Tax Cuts and Jobs Act” (the “Act”), and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law, many of which will...more

Goulston & Storrs PC

Tax Reform Advisory: Real Estate Industry

Goulston & Storrs PC on

On December 22, 2017, the President signed into law H.R. 1, informally known as the “Tax Cuts and Jobs Act” (the “Act”). The Act will have a significant impact on many sectors of the economy including the real estate sector....more

Goulston & Storrs PC

Tax Reform Advisory: Corporate and General Business Provisions

Goulston & Storrs PC on

On December 22, 2017, the President signed into law H.R. 1, informally known as the “Tax Cuts and Jobs Act” (the “Act”), implementing sweeping changes to the United States tax regimes generally applicable to businesses. ...more

Goodwin

Impact of Tax Reform on the Private Equity Industry

Goodwin on

On December 22, 2017, President Trump signed the revised tax reform bill (the Bill) into law. The Bill enacts the most sweeping changes to the Internal Revenue Code since the Tax Reform Act of 1986 and will significantly...more

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