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UBTI Limited Liability Company (LLC)

Proskauer Rose LLP

Proskauer’s Hedge Start: Key Tax Issues

Proskauer Rose LLP on

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

Troutman Pepper

Proposed Regulations Provide Guidance on Unrelated Business Taxable Income (UBTI) Calculation

Troutman Pepper on

On April 24, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations with respect to Section 512(a)(6) of the Internal Revenue Code. These regulations are designed to provide guidance on...more

Proskauer - Tax Talks

Proposed Regulations on UBTI Provide Guidance to Tax-Exempt Organizations Making Fund Investments

Proskauer - Tax Talks on

On April 23, 2020, the Treasury Department and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 512(a)(6) of the Internal Revenue Code (the “Code”). Section...more

Farrell Fritz, P.C.

New York City’s Unconscionable . . . Unexpected . . . Unincorporated Business Tax – A Glimpse Of...

Farrell Fritz, P.C. on

Hell of a Town- Ask most New Yorkers what New York City has in abundance and you’ll get responses that are as varied as the personalities to whom the question is put. Museums, restaurants, performing arts, college...more

Troutman Pepper

Final Noncompensatory Partnership Options Regulations Could Affect the Tax Treatment of Penny Warrants and Other Arrangements

Troutman Pepper on

Investments in partnerships (and other pass-through entities such as limited liability companies treated as a partnership) often involve the acquisition of warrants, options or other rights to acquire securities. This is...more

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