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
At a time marked by themes of “push” and “pull,” organizations across all sectors and jurisdictions are grappling with the pursuit of innovation within an increasingly complex regulatory framework. Over the next 12 months,...more
In response to a shortage of affordable middle-income housing in the United States, legislators recently introduced the Workforce Housing Tax Credit Act, which includes significant financial incentives for developers, to help...more
Private equity, hedge fund, and other investment fund sponsors should be aware of the recent development in the Internal Revenue Service’s (IRS’s) audit campaign with respect to potential liability for Self-Employment...more
The Inflation Reduction Act of 2022 opened up many energy credit opportunities for tax-exempt organizations. The Internal Revenue Service (IRS) and US Treasury Department released on June 14, 2023 proposed regulations on the...more
Creating a financial technology (fintech) firm comes with a host of tax considerations and implications. Decisions about the business’s structure, along with the location of both the business itself as well as its employees,...more
A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a...more
The Inflation Reduction Act of 2022 opened up many energy credit opportunities for tax-exempt organizations. Further guidance on the credit regime is anticipated in the coming months, which should help organizations determine...more
Private equity, hedge fund, and other investment fund sponsors should be aware that there continue to be significant developments in the Internal Revenue Service's (IRS’s) audit campaign with respect to the potential...more
The Internal Revenue Service and the US Department of the Treasury pre-released final regulations, T.D. 9945, under Section 1061 on January 7, providing guidance to the holders of certain carried interests. These rules are of...more
A new coronavirus (COVID-19) relief bill—the Consolidated Appropriations Act, 2021, which includes the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (the Act)—was signed into law on December 27. The Act not only...more
1/4/2021
/ Consolidated Appropriations Act (CAA) ,
Energy Projects ,
Green Technology ,
Infrastructure ,
Investment Tax Credits ,
New Legislation ,
Offshore Wind ,
Production Tax Credit ,
Renewable Energy ,
Solar Energy ,
Tax Planning ,
Wind Power
The Internal Revenue Service (IRS) and the US Treasury Department released proposed regulations (REG-107213-18) under Section 1061 on July 31 providing guidance to the holders of certain carried interests. These rules are of...more
8/7/2020
/ Capital Gains ,
Carried Interest Tax Rates ,
Financial Services Industry ,
IRS ,
Partnership Interests ,
PFIC ,
Private Investment Funds ,
S-Corporation ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
Revenue Procedure 2020-22 from the Internal Revenue Service provides helpful flexibility for taxpayers in a real property trade or business. ...more