In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more
1/31/2025
/ Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Private Equity Funds ,
Private Funds ,
Regulatory Requirements ,
Tax Court ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Reform ,
U.S. Treasury
2023 saw a number of key tax developments that may affect the private fund industry going into 2024, from key US Tax Court opinions and updates to Internal Revenue Service (IRS) Forms, to new regulations proposed by the IRS...more
The US Department of Treasury recently released final regulations providing guidance on the exception from taxation under the Foreign Investment in Real Property Tax Act of 1980 for “qualified foreign pension funds” under...more
The Internal Revenue Service (IRS) issued proposed regulations under Sections 892 and 897 of the Internal Revenue Code of 1986, as amended, on December 29, 2022. Final regulations under Section 897 regarding the exemption...more
The Internal Revenue Service announced that it has revised the Employer Identification Number application process in order to provide greater security and improve transparency. The revision will require that each applicant’s...more
New provisions will have a significant impact on secondary sales of fund interests and partnership M&A transactions.
On December 22, 2017, US President Donald Trump signed into law the sweeping tax reform bill H.R. 1 (the...more
US Tax Court decision may facilitate tax-efficient investment structures for non-US investors investing in US operating partnerships, directly or through investment funds....more
The recently proposed regulations, if finalized, would govern the treatment of RICs’ income inclusions in respect of CFCs and PFICs for purposes of the income test applicable to RICs; in related guidance, the IRS also...more
IRS Notice postpones several key deadlines and provides other relief.
On September 18, the US Internal Revenue Service (IRS) released Notice 2015-66 (the Notice) announcing that the US Department of the Treasury and the...more
9/28/2015
/ Amended Regulation ,
FATCA ,
FATCA Timeline ,
Foreign Financial Institutions (FFI) ,
Global Intermediary Identification Number (GIIN) ,
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Intergovernmental Agreements ,
IRS ,
Pro Rata Allocation Rule ,
U.S. Treasury ,
Withholding Requirements