The US House of Representatives on May 22, 2025 passed the One Big Beautiful Bill Act (the Act), which includes a tax package that would extend certain provisions of the 2017 Tax Cuts and Jobs Act set to expire at the end of...more
In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more
1/31/2025
/ Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Private Equity Funds ,
Private Funds ,
Regulatory Requirements ,
Tax Court ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Reform ,
U.S. Treasury
2023 saw a number of key tax developments that may affect the private fund industry going into 2024, from key US Tax Court opinions and updates to Internal Revenue Service (IRS) Forms, to new regulations proposed by the IRS...more
The US Department of Treasury recently released final regulations providing guidance on the exception from taxation under the Foreign Investment in Real Property Tax Act of 1980 for “qualified foreign pension funds” under...more
The Internal Revenue Service (IRS) issued proposed regulations under Sections 892 and 897 of the Internal Revenue Code of 1986, as amended, on December 29, 2022. Final regulations under Section 897 regarding the exemption...more
Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more
3/9/2021
/ Corporate Taxes ,
Financial Services Industry ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Investment Management ,
IRS ,
Private Investment Funds ,
Sovereign Wealth Funds ,
Tax Assessment ,
Tax Evasion ,
Tax Liability
The Internal Revenue Service recently released Revenue Ruling 2020-27 and Revenue Procedure 2020-51, which provide guidance on the deductibility of certain expenses paid or incurred in a taxpayer’s business using loan...more
12/7/2020
/ Business Expenses ,
CARES Act ,
Coronavirus/COVID-19 ,
Federal Loans ,
IRS ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
SBA Lending Programs ,
Tax Deductions ,
Tax Planning ,
Tax Relief
Revenue Procedure 2020-22 from the Internal Revenue Service provides helpful flexibility for taxpayers in a real property trade or business. ...more
The Internal Revenue Service announced that it has revised the Employer Identification Number application process in order to provide greater security and improve transparency. The revision will require that each applicant’s...more
New provisions will have a significant impact on secondary sales of fund interests and partnership M&A transactions.
On December 22, 2017, US President Donald Trump signed into law the sweeping tax reform bill H.R. 1 (the...more
US Tax Court decision may facilitate tax-efficient investment structures for non-US investors investing in US operating partnerships, directly or through investment funds....more