Key Points -
Fund-level liability for a buyer’s failure to withhold upon secondary market transfer of an LP interest in a fund with ECI assets will apply only for transfers on or after January 1, 2023.
Certain...more
8/27/2021
/ Corporate Taxes ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Limited Partnerships ,
Master Limited Partnerships ,
Partnerships ,
Publicly-Traded Companies ,
Secondary Markets ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Transfer of Interest
The Coronavirus Aid, Relief and Economic Security Act (CARES Act) (P.L. 116-136), signed into law March 27, contained numerous business relief provisions, one of which was a repeat from the 2008-2009 financial crisis. While...more
On March 25, 2020, the U.S. Senate released final text of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (H.R. 748) to provide emergency economic assistance to those affected by the novel coronavirus...more
3/30/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Employee Retention ,
Federal Taxes ,
Financial Stimulus ,
Income Taxes ,
IRS ,
Net Operating Losses ,
Payroll Taxes ,
Tax Code ,
Tax Credits ,
Tax Deductions ,
Tax Relief
• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more
10/8/2018
/ Asset Management ,
Certifications ,
Common Reporting Standard (CRS) ,
Controlling Person ,
Derivatives ,
FATCA ,
FBAR ,
Filing Deadlines ,
Foreign Investment ,
Form W-8 ,
Gross Proceeds ,
Income Taxes ,
Intergovernmental Agreements ,
Investment Funds ,
Investment Management ,
Investors ,
IRS ,
OECD ,
Reporting Requirements ,
Section 871(m) ,
Swaps ,
Withholding Tax
The Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, resulted in a fundamental change in the way the U.S. Internal Revenue Service (IRS) will conduct audits of collective...more
11/22/2017
/ Asia ,
Bipartisan Budget Act ,
Foreign Financial Institutions (FFI) ,
Fund Managers ,
Hedge Funds ,
Income Taxes ,
Investors ,
IRS ,
New Amendments ,
Partnerships ,
Private Equity Funds ,
Protecting Americans from Tax Hikes (PATH) Act ,
Tax Audits ,
Tax Liability ,
Tax Returns
• Significant corporate and potential individual tax rate reductions and a 25% individual tax rate on certain “qualified business income” would be introduced (although many fund investors and sponsors would not be eligible...more
11/8/2017
/ Asset Management ,
Blocker Corporations ,
Business Taxes ,
Carried Interest ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
Investment Funds ,
Management Fees ,
Proposed Legislation ,
Reconciliation ,
REIT ,
SALT ,
Tax Cuts ,
Tax Rates ,
Tax Reform ,
UBTI ,
Ways and Means Committee
On September 5, 2014, the Office of Chief Counsel, Internal Revenue Service (IRS) released an internal generic legal advice memorandum advising an IRS field agent that the statutorily provided “limited partner” exception to...more
The Department of the Treasury and the Internal Revenue Service (IRS) announced today (available here) that they are delaying the implementation by two years—until January 1, 2016—of final expanded regulations governing the...more