Private equity, hedge fund, and other investment fund sponsors should be aware of the recent development in the Internal Revenue Service’s (IRS’s) audit campaign with respect to potential liability for Self-Employment...more
A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a...more
Private equity, hedge fund, and other investment fund sponsors should be aware that there continue to be significant developments in the Internal Revenue Service's (IRS’s) audit campaign with respect to the potential...more
The Inflation Reduction Act of 2022, signed by US President Joseph Biden on August 16, 2022, includes a new alternative minimum tax for corporations with profits of more than $1 billion....more
The Internal Revenue Service and the US Department of the Treasury pre-released final regulations, T.D. 9945, under Section 1061 on January 7, providing guidance to the holders of certain carried interests. These rules are of...more
The Internal Revenue Service (IRS) and the US Treasury Department released proposed regulations (REG-107213-18) under Section 1061 on July 31 providing guidance to the holders of certain carried interests. These rules are of...more
8/7/2020
/ Capital Gains ,
Carried Interest Tax Rates ,
Financial Services Industry ,
IRS ,
Partnership Interests ,
PFIC ,
Private Investment Funds ,
S-Corporation ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
The US Internal Revenue Service (IRS) issued proposed regulations on May 7 that would expand tax withholding and reporting requirements in certain sales or exchanges of interests in partnerships engaged in one or more US...more
The proposed modifications would create opportunities for enhanced CFC credit support.
On October 31, 2018, the US Treasury Department and the Internal Revenue Service (IRS) released proposed Treasury Regulations (the...more
The Internal Revenue Service announces forthcoming regulations in relation to “ECI withholding” under Section 1446(f). It also announces interim relief and guidance for taxpayers pending regulations....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
Sponsoring entities should evaluate which of their sponsored entities should be registered via the IRS registration portal....more
The final, temporary, and proposed regulations issued by the Internal Revenue Service on October 13 relating to intercompany debt obligations between members of an affiliated group of corporations under Section 385 of the...more
11/3/2016
/ Collateralized Debt Obligations ,
Corporate Counsel ,
Foreign Corporations ,
Intercompany Transactions ,
Internal Revenue Code (IRC) ,
IRS ,
Multinationals ,
Parent Corporation ,
Private Equity ,
Proposed Regulation ,
Registered Investment Companies (RICs) ,
REIT ,
S-Corporation ,
Section 385 ,
Stocks
The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more
7/28/2015
/ Enterprise Risks ,
Fee Waivers ,
Internal Revenue Code (IRC) ,
Intra-Group Transactions ,
Investment Management ,
IRS ,
Management Fees ,
Proposed Regulation ,
Safe Harbors ,
Taxable Distributions ,
U.S. Treasury
Are you a day late? -
On March 5, the Internal Revenue Service (the IRS) published proposed regulations (REG-100400-14, RIN 1545-BM14) (the Proposed Regulations) that would place strict new guidelines on the “next-day...more
Certain individuals who have only signature authority over foreign financial accounts now have until June 30, 2016 to file the Report of Foreign Bank and Financial Accounts....more
The IRS notice further eases, but does not delay, FATCA implementation.
On May 2, the Internal Revenue Service (IRS) published Notice 2014-33 (the Notice), which announced that calendar years 2014 and 2015 will be...more
Foreign financial institutions, such as offshore funds, should register with the IRS by May 5 and review new and revised IRS forms.
The July 1 start date for Foreign Account Tax Compliance Act (FATCA) withholding on...more
IRS modifies rules allowing the deferral method of accounting for advance payments received for the sale of gift cards that are redeemable by an unrelated party.
On July 24, the Internal Revenue Service (IRS) released an...more
IRS notice postpones FATCA withholding by six months and revises other key deadlines.
...more
Certain individuals having only signature authority over foreign financial accounts now have until June 30, 2014, to file the Report of Foreign Bank and Financial Accounts.
...more