While the final regulations simplify key exceptions and contain favorable changes, ambiguity continues for investment fund managers.
On January 7, 2021, the US Treasury Department and Internal Revenue Service (together,...more
While the proposed carried interest regulations clarify key aspects, the proposed rules leave some ambiguity for investment fund managers.
Section 1061 is intended to limit long-term capital gain treatment attributable to...more
The First Circuit reverses a lower court decision and finds two Sun Capital private equity funds are not liable for portfolio company’s pension plan liabilities under ERISA.
On November 22, 2019, the United States Court of...more
Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects.
On November 26, 2018, the Treasury and...more
12/20/2018
/ C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
GILTI tax ,
Interest Payments ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
REIT ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
U.S. Treasury
Recent guidance from Treasury clarifies fundamental aspects regarding the investment of deferred capital gains in QOFs.
Key Points:
..Investors in qualified opportunity funds may derive significant tax benefits in the...more
11/7/2018
/ Capital Gains ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Tax Deferral ,
U.S. Treasury
The guidance shows Treasury Regulations will ease administrative challenges and exclude certain transfers from the new withholding regime.
Key Points:
..Taxpayers can deliver IRS Form W-9 or an affidavit to establish...more
Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context.
Key Points:
..The legislation alters fundamental aspects of US business taxation...more
1/11/2018
/ Corporate Taxes ,
Energy Sector ,
Mortgage REITS ,
Multinationals ,
Net Operating Losses ,
Private Investment Funds ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
Aspects of the current proposals could significantly alter the US taxation of investment funds, sponsors, and investors.
Key Points:
..Major changes to US tax laws on business tax rates, interest deductibility, and...more