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Private Fund Industry Update: the Key Tax Developments That Shaped 2023

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 Trends—and Traps—that Will Shape 2024

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

US Senators and Representatives Propose Bipartisan Workforce Housing Tax Credit Act

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

US Tax Court Decision Opens Limited Partners to Self-Employment Tax Exposure

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

Inflation Reduction Act Guidance Proposed on Direct Payment for Energy Credits

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

Tax Considerations and Pitfalls to Avoid for Fintech Startups

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

Taxpayer Victory in US Tax Court Highlights Need for Properly Structuring Partnership Profits Interests

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

Inflation Reduction Act Guidance Anticipated on Direct Payment for Energy Credits

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

US Tax Court Will Weigh In on Self-Employment Tax for Limited Partners

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

IRS Issues Final Regulations on Carried Interests

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

New COVID-19 Relief Legislation Extends Renewable Energy and Green Technology Industry Tax Incentives

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

IRS Issues Proposed Regulations on Carried Interests

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

IRS Provides Guidance on Elections Related to Section 163(j) Business Interest Limitation

Revenue Procedure 2020-22 from the Internal Revenue Service provides helpful flexibility for taxpayers in a real property trade or business. ...more

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