The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) on July 31, 2020 issued long-awaited proposed regulations (the “Proposed Regulations”) providing guidance under section 1061...more
8/13/2020
/ Capital Gains ,
Carried Interest ,
Fund Managers ,
IRS ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
REIT ,
RICs ,
S-Corporation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
The Opportunity Zone program created by the Tax Cuts and Jobs Act of 2017 (the “TCJA”) allows taxpayers that realize certain gains to elect to defer the federal income tax on such gains by reinvesting them into Qualified...more
10/24/2018
/ Business Taxes ,
Capital Gains ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning
President Trump signed into law tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”) on December 22, 2017. The Tax Act implemented the most far-reaching changes to the Internal Revenue Code (the...more
4/9/2018
/ Base Erosion Tax ,
Business Expenses ,
Capital Gains ,
Carried Interest Tax Rates ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Exports ,
GILTI tax ,
Global Market ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
Local Taxes ,
Multinationals ,
Net Operating Losses ,
Pass-Through Entities ,
Portfolio Companies ,
Private Equity ,
Private Equity Funds ,
Repatriation ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Exemptions ,
Tax Rates ,
Trump Administration
A recent U.S. Tax Court case, Grecian Magnesite (149 T.C. No. 3, July 13, 2017), has declared invalid the long-standing U.S. government position that a non-U.S. person’s sale of an interest in a partnership (in this case, a...more
7/19/2017
/ Capital Gains ,
Foreign Investment ,
Foreign-Owned Corporations ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Non-Resident Income Taxes ,
Partnership Interests ,
Partnerships ,
Reversal ,
Tax Court ,
Transfer of Interest
All eyes are on Washington—or should we say Manhattan—these days, searching for clues about where our ship is heading with U.S. President-elect Donald Trump at the helm. Recently, there have been cabinet appointments to...more
1/6/2017
/ Affordable Care Act ,
Capital Gains ,
Clean Water Act ,
Corporate Taxes ,
Deregulation ,
Dodd-Frank ,
Energy Sector ,
Financial Stimulus ,
Foreign Investment ,
Fossil Fuel ,
Infrastructure ,
Initial Public Offering (IPO) ,
Merger Controls ,
National Security ,
Pass-Through Entities ,
Permits ,
Private Equity ,
Repeal ,
Tax Reform ,
Trump Administration ,
Volcker Rule
India and Mauritius entered into a Protocol amending the double-tax treaty between India and Mauritius (the “2016 Protocol”) on May 10, 2016. Under the 2016 Protocol, following a grace period and subject to a grandfather...more