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
On April 24, the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding Section 897. In December 2022, the IRS issued proposed regulations under Sections 897 (the Proposed Regulations) and 892...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
Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more
3/9/2021
/ Corporate Taxes ,
Financial Services Industry ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Investment Management ,
IRS ,
Private Investment Funds ,
Sovereign Wealth Funds ,
Tax Assessment ,
Tax Evasion ,
Tax Liability
Revenue Procedure 2020-22 from the Internal Revenue Service provides helpful flexibility for taxpayers in a real property trade or business. ...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
The PATH Act exempts certain foreign pension funds from taxation under FIRPTA and significantly modifies the tax rules applicable to REITs.
On December 18, 2015 (Enactment Date), US President Barack Obama signed the...more
1/6/2016
/ FIRPTA ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
Pension Funds ,
Protecting Americans from Tax Hikes (PATH) Act ,
Real Estate Investments ,
Registered Investment Companies (RICs) ,
REIT ,
Securities and Exchange Commission (SEC) ,
Shareholders ,
Spinoffs