On August 12, 2022, the U.S. Congress passed the Inflation Reduction Act of 2022 (the “Act”), which was signed into law by President Biden on August 16, 2022. Alongside sweeping changes to energy, environmental and...more
8/26/2022
/ Alternative Minimum Tax ,
American Rescue Plan Act of 2021 ,
Business Losses ,
CARES Act ,
Corporate Taxes ,
Excise Tax ,
Fair Market Value ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
New Legislation ,
Publicly-Traded Companies ,
Shareholders ,
Stock Repurchases ,
U.S. Treasury
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
U.S. Senate Finance Committee Chair Ron Wyden (D-Ore.) and Senator Sheldon Whitehouse (D-R.I.) on August 5, 2021, introduced legislation entitled the “Ending the Carried Interest Loophole Act” (the “Wyden Bill”)....more
The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) on July 31, 2020 issued long-awaited proposed regulations (the “Proposed Regulations”) providing guidance under section 1061...more
8/13/2020
/ Capital Gains ,
Carried Interest ,
Fund Managers ,
IRS ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
REIT ,
RICs ,
S-Corporation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On December 13, 2018, U.S. Department of the Treasury and the Internal Revenue Service released proposed regulations (the “Proposed Regulations”) that would amend the current regulations relating to the Foreign Account Tax...more
12/19/2018
/ Common Reporting Standard (CRS) ,
FATCA ,
Financial Institutions ,
Foreign Financial Institutions (FFI) ,
HIRE Act ,
IRS ,
Mutual Funds ,
Non-Residents ,
OECD ,
Private Funds ,
Proposed Amendments ,
Regulatory Burden ,
U.S. Treasury ,
Withholding Requirements
The U.S. Department of the Treasury (the “Treasury”) and the U.S. Internal Revenue Service (the “IRS”) have issued a new installment of proposed regulations under the centralized partnership audit regime included in the...more
The U.S. Bipartisan Budget Act of 2015 amended the provisions of the U.S. Internal Revenue Code of 1986, as amended (Code), governing partnership audit proceedings. The new provisions are designed to simplify the ability of...more
The U.S. Internal Revenue Service (the “IRS”) has released Notice 2016-76, providing anticipated guidance and transition relief for certain dividend equivalent transactions described in section 871(m) of the U.S. Internal...more
12/7/2016
/ Dividend-Equivalent Transactions ,
Dividends ,
Exchange-Traded Products ,
Extensions ,
Foreign Persons ,
HIRE Act ,
IRS ,
Qualified Derivatives Dealers (QDDs) ,
Section 871(m) ,
Swaps ,
Withholding Tax
The U.S. Internal Revenue Service (the “IRS”) plans to release a guidance package including final rules and transition relief for dividend equivalent transactions described in Section 871(m) of the U.S. Internal Revenue Code...more
There has been buzz in the tax and private equity communities about the rise in audits of private equity firms by the Internal Revenue Service (“IRS”). This has been fueled by the restructuring of the IRS’ Large Business &...more
Congress recently amended the rules governing tax audits of partnerships that file U.S. partnership returns, including U.S. partnerships (and limited liability companies treated as partnerships) and certain non-U.S....more
The recently enacted Bipartisan Budget Act of 2015 amended existing Internal Revenue Code of 1986, as amended (the “Code”) rules governing tax audits of partnerships in the U.S. These new rules primarily impact partnerships...more
The Common Reporting Standard (“CRS”) will impose new investor due diligence and reporting obligations on funds and other financial institutions based in “early adopter” participating jurisdictions, with effect from January...more
The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) have issued proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the “Code”), covering the...more
Sections 1471 through 1474 of the U.S. Internal Revenue Code (“FATCA”) generally impose a 30% withholding tax on certain payments to a foreign financial institution (“FFI”) unless the FFI has entered into an agreement with...more
The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released final regulations (“Regulations”) on January 17, 2013 implementing the Foreign Account Tax Compliance Act (“FATCA”).1...more
On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “Regulations”) implementing foreign account reporting provisions of the...more
2/11/2013
/ Collateralized Debt Obligations ,
Due Diligence ,
FATCA ,
Foreign Financial Accounts ,
Global Intermediary Identification Number (GIIN) ,
Intergovernmental Agreements ,
Investment Funds ,
IRS ,
Portal ,
Required Documentation ,
U.S. Treasury ,
Withholding Requirements