Recent law changes can provide portfolio company liquidity and/or require reconsideration of 2018–2020 deals. During this webinar, Steven D. Bortnick and Todd B. Reinstein, partners in the Tax and Estates Practice Group of...more
6/26/2020
/ Acquisitions ,
Alternative Minimum Tax ,
CARES Act ,
Carryback Rules ,
Income Taxes ,
Mergers ,
Net Operating Losses ,
Portfolio Companies ,
Private Equity ,
Separation Agreement ,
Tax Credits ,
Tax Planning
At this point, private equity firms are very conscious that debt of their U.S. acquisition vehicles or portfolio companies cannot be guaranteed by controlled foreign corporations (CFCs), nor can more than 65 percent of the...more
As we previously reported, following the tax reform package passed in December, private equity limited partner investors based outside the United States are now subject to tax on gains from the sale of partnership interests....more
4/27/2018
/ Capital Gains ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Partnership Interests ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
Withholding Tax
More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more
3/19/2018
/ Capital Gains ,
Foreign Investment ,
Income Taxes ,
IRS ,
Limited Partnerships ,
Partnership Interests ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Trump Administration ,
Withholding Tax
On February 26, 2014, U.S. Rep. David Camp (R-MI), chairman of the House Ways and Means Committee, released a draft of the Tax Reform Act of 2014 (TRA 2014), which would provide for the most significant tax reform since the...more
Investment funds that invest globally must deal with volatility in the currency in which they agree to invest. Investment funds entering into obligations to purchase stock in a currency other than the primary currency of the...more