On December 15, 2025, the US Department of the Treasury and the Internal Revenue Service (IRS) published final regulations and proposed regulations under Section 892 of the Internal Revenue Code relating to the taxation of...more
1/12/2026
/ Cross-Border Transactions ,
Final Rules ,
Foreign Governments ,
Foreign Investment ,
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Internal Revenue Code (IRC) ,
International Tax Issues ,
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New Regulations ,
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Sovereign Wealth Funds ,
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U.S. Treasury
Under a regulation recently finalized by the California Franchise Tax Board (FTB), fees received by asset managers may be subject to income tax in California based on the domicile of a fund’s underlying investors or...more
12/5/2025
/ Asset Management ,
Beneficial Owner ,
California ,
Final Rules ,
Franchise Tax Board ,
Fund Managers ,
Income Taxes ,
Investment Funds ,
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Non-Domiciled Investors ,
Pass-Through Entities ,
Private Funds ,
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State Taxes ,
Tax Planning