Key Points -
The broader application of Section 871(m) has again been delayed, this time until January 1, 2025, and, as a result, investment funds with non-U.S. feeders or investors up the chain should generally expect to...more
• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more
10/25/2018
/ Asset Management ,
Capital Assets ,
Capital Gains ,
Community Development ,
Economic Development ,
Fund Sponsors ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Low-Income Issues ,
New Rules ,
Opportunity Zones ,
Partnerships ,
Proposed Regulation ,
Public Finance ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Rollover Equity ,
Safe Harbors ,
State and Local Government ,
Tax Benefits ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Exemptions ,
Tax Incentives ,
Tax Reform ,
U.S. Treasury ,
Value Appreciation
• The broader application of Section 871(m) has been delayed further until January 1, 2021 and, as a result, investment funds with non-U.S. feeders or investors up the chain should generally expect to incur U.S. withholding...more
9/24/2018
/ Anti-Abuse Rule ,
Broker-Dealer ,
Delays ,
Derivatives ,
Dividend-Equivalent Transactions ,
Equity Investors ,
Exchange-Traded Products ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
IRS ,
Qualified Derivatives Dealers (QDDs) ,
Section 871(m) ,
Swaps ,
Tax Evasion ,
Withholding Tax
In response to perceived abuses in taxpayers’ use of swaps and other derivative transactions (e.g., options, futures or forwards) to avoid withholding tax on U.S. source dividends, Congress added Section 871(m) to the...more
8/18/2017
/ Anti-Abuse Rule ,
Broker-Dealer ,
Delays ,
Derivatives ,
Dividend-Equivalent Transactions ,
Equity Investors ,
Exchange-Traded Products ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
IRS ,
Section 871(m) ,
Swaps ,
Tax Evasion ,
Withholding Tax