Key Points Internal IRS correspondence in the form of a recent Chief Counsel Memorandum concludes that funds structured as partnerships (e.g., master funds in a standard master-feeder structure) must determine the...more
Key Points -
Recently proposed regulations would significantly curtail the ability for private fund sponsors and non-U.S. investors to use a so-called D-REIT to facilitate a tax-efficient exit from U.S. real property...more
• Significant corporate and potential individual tax rate reductions and a 25% individual tax rate on certain “qualified business income” would be introduced (although many fund investors and sponsors would not be eligible...more
11/8/2017
/ Asset Management ,
Blocker Corporations ,
Business Taxes ,
Carried Interest ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
Investment Funds ,
Management Fees ,
Proposed Legislation ,
Reconciliation ,
REIT ,
SALT ,
Tax Cuts ,
Tax Rates ,
Tax Reform ,
UBTI ,
Ways and Means Committee
On the same day as President Obama’s speech championing solar, the Department of the Treasury proposed regulations defining “real estate assets” for purposes of the definition of a real estate investment trust (REIT). The...more