Section 1402(a)(13) of the Internal Revenue Code provides that the distributive share of “limited partners, as such” from a partnership is not subject to self-employment tax.[1] Managers of private equity and hedge funds are...more
On May 13, 2019, the U.S. Internal Revenue Service (“IRS”) and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions...more
5/23/2019
/ FIRPTA ,
Foreign Persons ,
Income Taxes ,
International Tax Issues ,
IRS ,
K-1 ,
Partnerships ,
Proposed Regulation ,
Reporting Requirements ,
Shareholders ,
Withholding Requirements
On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more
4/23/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
Tax Reform
On April 2, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-29 (the “Notice”), announcing the intention of the IRS and the Department of the Treasury to issue regulations regarding the withholding requirements...more
5/9/2018
/ FIRPTA ,
Foreign Investment ,
Income Taxes ,
Interim Guidance ,
International Tax Issues ,
IRS ,
Limited Partnerships ,
Partnership Interests ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Reform ,
Withholding Tax
On July 22, 2015, the U.S. Department of the Treasury and U.S. Internal Revenue Service issued proposed Treasury Regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended, addressing management...more
7/27/2015
/ Capital Gains ,
Deferred Compensation ,
Enterprise Risks ,
Fee Waivers ,
Fund Managers ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Management Fees ,
Private Investment Funds ,
Proposed Regulation ,
U.S. Treasury