On April 12, 2024, the Department of the Treasury and the IRS published proposed regulations regarding the application of the stock repurchase excise tax under § 4501 of the Internal Revenue Code (the “Proposed Regulations”)....more
Under current (post-2017) federal income tax law, long-term capital gain allocated to or realized by a non-corporate recipient of a promote or other performance-based allocation (a "Carried Interest") in the investment...more
In the midst of a downturn in the US economy during the COVID-19 pandemic, structuring transactions in a tax efficient manner will become an even more critical component of achieving optimal investment returns. For example,...more
Key Points -
- As economic pressure intensifies on borrowers, we anticipate debt restructuring and workout transactions will become increasingly necessary. Similarly, dislocations in the debt markets may present...more