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Final Carried Interest Regulations: Key Takeaways for Private Fund Sponsors

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

Proposed Carried Interest Regulations Leave Unanswered Questions

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

Investment Funds: Sun Capital Reversal Offers Important Takeaways Regarding Portfolio Company Pension Liabilities

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

IRS Issues Proposed Regulations on Business Interest Deduction Limitations

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

Qualified Opportunity Funds: Investment and Structuring Considerations

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

Withholding Guidance Issued on Sale of Interests in a Partnership with US Assets

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

US Tax Reform: Key Business Impacts, Illustrated With Charts and Transactional Diagrams

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

How US Tax Reform Proposals Will Affect Private Investment Funds and Asset Managers

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

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