The plan would tax all capital gains as ordinary income; end deferral of capital gains tax for the wealthy -
Senate Finance Committee Ranking Member Ron Wyden (D-OR) recently released a proposal, “Treat Wealth Like Wages,”...more
INTRODUCTION -
On July 15, 2019, the staffs of the Securities and Exchange Commission (“SEC”) and the North American Securities Administrators Association issued a joint statement (the “Staff Statement”) to assist...more
Restoring accountability measures stripped during tax reform could be good news for those concerned about gentrification but may result in reputational risks and additional costs for OZ Funds -
As we anticipated in our...more
After a lengthy drafting and protracted review process, the Department of Treasury (“Treasury”) has released its second set of proposed regulations (the “Second Round Regs”) providing guidance on the implementation of the...more
5/6/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning
Yesterday, the Treasury Department rolled out proposed Opportunity Zone (“OZ”) regulations (the “Proposed Regulations”) and President Trump noted the progress made by his Opportunity and Revitalization Council to eliminate...more
In December 2017, Congress enacted The Tax Cuts and Jobs Act (the “Tax Cuts Act”). Included in that tax legislation is what has come to be called the opportunity zone incentive (“OZ Incentive”): a host of dramatic new tax...more
Treasury decisions could make or break OZ for operating businesses -
Eagerly anticipated proposed regulations addressing the eligibility of operating businesses to qualify for Opportunity Zone (OZ) benefits are in the final...more
3/26/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
Investors ,
IRS ,
Opportunity Zones ,
Popular ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments
Order is aimed at cutting red tape and improving coordination among federal, state, and local agencies - On December 12, President Trump issued an Executive Order (the “Executive Order”) establishing the White House...more
The Tax Cuts and Jobs Act (the “Act”) created a significant new tax incentive for taxpayers that invest capital gains in Qualified Opportunity Funds (each a “QOF” and collectively, “QOFs”). Investors can defer paying tax on...more
10/30/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Deferral
Long-awaited guidance expected to trigger a surge of green-lighted projects as investors race to meet holding periods, creating competition for investment dollars and desirable OZ developments and businesses -
The...more
The Internal Revenue Service (“IRS”) has released proposed regulations explaining how taxpayers should calculate the Section 199A deduction for qualified business income. ...more
Among the more noteworthy changes made by the Tax Cuts and Jobs Act of 2017 was the creation of Code Section 199A, which grants a deduction to owners of certain pass-through businesses (i.e., sole proprietorships,...more
The global private equity fund industry remained strong in 2017, as both established and first-time fund managers launched new funds and deployed the capital of existing ones. We saw a diverse range of managers and strategies...more
The Tax Cuts and Jobs Act – Material Impact on Private Funds -
On December 22, 2017, the president signed the tax reform bill formerly known as the Tax Cuts and Jobs Act (the TCJA). While the TCJA will impact many types of...more
3/5/2018
/ Business Income ,
Business Taxes ,
C-Corporation ,
Capital Gains ,
Corporate Taxes ,
International Tax Issues ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
The tax reform bill signed into law by President Trump on December 22, 2017, taxes U.S. shareholders on their share of the previously untaxed deferred income of foreign corporations. Known as “deemed repatriation,” this tax...more
In addition to the very significant changes to the domestic provisions of the Internal Revenue Code (the “Code”), the Tax Cut and Jobs Act (the “Act”) made very significant changes to the taxation of foreign income of U.S....more
On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the “Act”). While the Act will impact many types of taxpayers, some of the more significant changes are relevant to private funds, investment advisers,...more
On December 22, 2017, the president signed the Tax Cuts and Jobs Act (the “Act”). While the Act will impact many taxpayers, some of the more significant changes relate to how individuals and other non-corporate taxpayers are...more
In a recently published decision, the U.S. Tax Court declined to follow the longstanding position of the U.S. Internal Revenue Service (“IRS”), articulated in Revenue Ruling 91-32, that a non-U.S. partner’s gain or loss from...more
On December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”). Among its numerous revisions to federal tax law, the PATH Act significantly amended various...more
On October 5, 2015, the Organisation for Economic Co-operation and Development (“OECD”) published final reports outlining the “actions” to be undertaken by OECD members as part of the base erosion and profit shifting (“BEPS”)...more
For U.S. federal income tax purposes, a purchaser in a corporate acquisition typically prefers to acquire assets of a target corporation (“Target”) rather than stock because a purchaser that acquires assets is able to “step...more
On January 17, 2013, the U.S. Treasury Department (“U.S. Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited final regulations on the Foreign Account Tax Compliance Act (“FATCA”). The final regulations...more