As the private equity (“PE”) and venture capital (“VC”) funds industry grows and matures in Asia, managers are increasingly looking to market interests in their funds to U.S.-based investors. However, many Asia-based managers...more
7/6/2023
/ Asia ,
Bank Holding Company Act ,
Broker-Dealer ,
CFIUS ,
CFTC ,
Employee Retirement Income Security Act (ERISA) ,
Exemptions ,
Financial Industry Regulatory Authority (FINRA) ,
FIRRMA ,
FOIA ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Company Act of 1940 ,
Investors ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Private Equity ,
Private Funds ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Taxation ,
Venture Capital ,
Volcker Rule
We looked at 28 deals across Asia that were signed or closed pre-COVID in which the buyer or a group of affiliated buyers acquired all or a significant majority of the outstanding equity of the target, examined the common key...more
As the private equity (“PE”) and venture capital (“VC”) funds industry grows and matures in Asia, managers are increasingly looking to market interests in their funds to U.S.-based investors. However, many Asia-based managers...more
8/28/2020
/ CFIUS ,
Employee Retirement Income Security Act (ERISA) ,
Exempt Reporting Advisers (ERAs) ,
Investors ,
Marketing ,
Private Equity ,
Private Funds ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Venture Capital ,
Volcker Rule
Investments in private companies by way of share purchases from existing shareholders (secondary transactions) raise a unique set of complexities, which are often overlooked. Share issuances in company-led financing rounds...more
On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the "Act") into law. Although the individual and collective impact of the Act may not be evident for some time, the Act is generally viewed by the real...more
On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the “Act”). The Act was ostensibly promoted as a means to encourage investment and to promote growth in the U.S. economy, while reducing harmful...more
On April 4, 2016, the Treasury Department and the Internal Revenue Service issued a sweeping package of new regulations intended to curtail inversion transactions (the “Regulations”). Many features of the Regulations had...more
On April 4th, the Internal Revenue Service (“IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 385 which could dramatically change how related-party indebtedness is treated for federal income tax...more
I. OVERVIEW -
A recently released legal memorandum by the Internal Revenue Service (IRS) Office of Chief Counsel, CCA 201606027 (the “Memorandum”), concluded that a so-called “bad boy guarantee” provided by a sponsor of...more
On September 14, 2015, the Internal Revenue Service (“IRS”) issued Notice 2015-59 (the “Notice”) and Revenue Procedure 2015-43 (the “Rev Proc”; together with the Notice, the “Spin-Off Guidance”). Under the Spin-Off Guidance,...more
9/18/2015
/ Corporate Taxes ,
Distribution Rules ,
IRS ,
New Guidance ,
Private Letter Rulings ,
REIT ,
Revenue Procedures ,
RICs ,
Shareholders ,
Spinoffs ,
Tax-Free Transfers
On February 3, 2015, the PRC State Administration of Taxation (“SAT”) released the Announcement of SAT Concerning Several Matters Relating to Corporate Income Tax on Indirect Transfer of Properties by Non-tax Resident...more
As our readers know, foreign investments into the People’s Republic of China (“PRC”) are typically structured through one or more holding companies domiciled in offshore jurisdictions. Planned and implemented properly, an...more