How Proposed Tax Reform Will Impact Private Equity

Foley & Lardner LLP

Both the House of Representatives and the Senate have proposed their own versions of tax reform (the “House Proposal” and “Senate Proposal”, respectively, and together, the “Proposals”) which will drastically change the current U.S. federal income tax structure and the Internal Revenue Code of 1986, as amended (the “Code”). Both Proposals will be effective for tax years beginning after December 31, 2017, though certain provisions have a later effective date. This Alert highlights the impact the Proposals will have on private equity and discuss the following topics:

  • Corporate and Individual Tax Rates
  • Tax Rates on Pass-Through Income
  • Interest Deductibility
  • State and Local Income Taxes
  • Carried Interest
  • Source of Gains Upon Transfer of Partnership Interest
  • State Pension Plans
  • Self-Employment Tax

Corporate and Individual Tax Rates

The current corporate tax rate is graduated, with a maximum marginal rate of 35 percent. The House Proposal eliminates the graduated tax rate structure and will apply a flat 20 percent rate, except in the case of personal service corporations, which would be subject to a 25 percent rate. The Senate Proposal also eliminates the graduated tax rate structure, and will apply a flat 20 percent rate for all corporations. The corporate tax rate of the Senate Proposal will be effective for tax years beginning after December 31, 2018.

Under current law, there are seven ordinary income tax brackets at 10 percent, 15 percent, 25 percent, 28 percent, 33 percent, 35 percent and 39.6 percent. The Senate Proposal changes these rates to 10 percent, 12 percent, 22.5 percent, 25 percent, 32.5 percent, 35 percent and 38.5 percent.

The House Proposal collapses the tax rate structure into four brackets at 12 percent, 25 percent, 35 percent and 39.6 percent. The House Proposal also creates a new tax bracket for owners of pass-through entities. A 9 percent tax rate would apply to the first $37,500 of an individual’s share ($75,000 if filing jointly) of active business income from a pass-through entity. This rate would gradually phase out for individuals who have greater than $75,000 in taxable income ($150,000 if filing jointly), and is fully phased out at $112,500 ($250,000 if filing jointly). The 9 percent rate will be gradually phased in over the next five years.

Tax Rates on Pass-Through Income

Under current law, owners of a pass-through entity report net income on their individual tax returns, which is subject to ordinary tax rates (as discussed above under “Corporate and Individual Tax Rates”). Under the House Proposal, a portion of net income that is distributed by the pass-through entity to the partners may be treated as “qualified business income,” and is subject to a maximum tax rate of 25 percent rather than ordinary income tax rates. For tax years that straddle December 31, 2017, the reduced rate will apply proportionately for the period after December 31, 2017.

“Qualified business income” under the House Proposal is meant to include all passive business activity and certain active business activity, reduced by carryover business losses and certain current year net business losses. It does not include income subject to preferential rates (e.g., capital gains or losses, dividends, interest and other generally passive types of income). The remaining portion of net business income that is not qualified business income will be taxed as ordinary income.

Under the Senate Proposal, an individual may generally deduct 17.4 percent of domestic qualified business income received from a pass-through entity. The amount of the deduction for qualified business income received from a partnership is limited to 50 percent of the W-2 wages of the individual. If the amount of qualified business income is less than zero, the amount of the loss will be deducted from the individual’s qualified business income in the following tax year. The deduction is phased out for certain income thresholds ($500,000 for married couples under the bill that passed the Senate Finance Committee).

“Qualified business income” under the Senate Proposal generally means the net amount of domestic income generated from the taxpayer’s business. It does not include amounts distributed to a partner who is acting outside of his or her capacity as a partner, or amounts that are guaranteed payments for services actually rendered to a partnership to the extent that the payment is in the nature of compensation for those services.

Individual investors in private equity funds that invest in portfolio companies organized as pass-through entities are generally eligible for the 25 percent tax rate under the House Proposal and the 17.4 percent deduction on qualified business income with respect to such investments. However, income received by individuals for their involvement in the management of the fund will not be eligible for the preferential rates.

Interest Deductibility

Under current law, a business is generally allowed to deduct all interest paid or accrued in the taxable year, subject to limitations. Under the House Proposal, “business interest” deductions are limited to the sum of “business interest income” plus 30 percent of the “adjusted taxable income” of the business. The amount of interest expense in excess of 30 percent of the business’s adjusted taxable income may be carried forward up to five years after the interest was paid or accrued, and will be deducted on a first-in, first-out basis.

“Adjusted taxable income” under the House Proposal means the taxable income of the taxpayer without regard to: (i) any item of income or loss not properly allocable to a trade or business; (ii) any business interest or business interest income; (iii) any net operating loss deduction; and (iv) any deduction for depreciation or amortization.

Although the business interest deduction limitation is determined at the entity level, special rules allow for the partners of a partnership to use any unused interest expense deductions. If the amount of business interest deductions is below the 30 percent cap, the limit on the amount allowed as a business interest deduction is increased by a partner’s distributive share of the partnership’s unused interest expense deductions. There are corresponding rules to prevent double counting of such unused interest expense deductions.

The Senate Proposal is generally the same as the House Proposal, except that “adjusted taxable income” includes the 17.4 percent pass-through deduction (as discussed under “Tax Rates on Pass-Through Income”), and does not include depreciation and amortization. The Senate Proposal also allows for interest expense deductions to be carried forward indefinitely.

The limitation on interest expense deductions will increase the cost of capital, particularly in the private equity context, where a significant amount of debt is often used to acquire a target company. This may cause private equity funds to reconsider how they finance acquisitions to avoid the payment of interest.

State and Local Taxes

Under current law, amounts paid for state and local income taxes and property taxes are fully deductible for both individuals and corporations on their U.S. federal taxes. The House Proposal repeals the state and local income tax deduction for individual taxpayers, and limits the deductibility for state and local property taxes to $10,000 ($5,000 for a married individual filing separately). Corporations will be able to continue to take these deductions.

Initially, the House Proposal was interpreted as allowing individual owners of pass-through entities to take such deductions. However, the House Ways and Means Committee Chairman later clarified that state and local income taxes paid by individual owners of pass-through entities would not be eligible for such deductions.

The Senate Proposal also repeals the state and local income tax deduction for individual taxpayers, but not for corporations. Unlike the House Proposal, the Senate Proposal eliminates the state and local property tax deduction entirely. There is still uncertainty at this time whether this provision applies to owners of pass-through entities.

This remains a controversial issue in both Proposals, and is likely to change before any tax bill is enacted.

Carried Interest

Under current law, profits paid to private equity fund managers that are generated from investments (commonly referred to as “carried interest”) held for more than one year are taxed at capital gains rates. Under the House Proposal, an investment must be held for more than three years to receive capital gains treatment. Such profits attributable to gains on investments held for three years or less will be taxed as short-term capital gains (which is taxed as ordinary income).

Moreover, to receive capital gains treatment, the gain must be derived from an “applicable partnership interest,” which is generally intended to account for a profits interest of a partnership. An applicable partnership interest includes any interest held in connection with the taxpayer’s substantial services in a trade or business that involves raising and returning capital and investing or trading in securities, commodities and/or certain other assets (which is generally intended to include a portfolio management business).

The Senate Proposal has no proposed change to carried interest.

The House Proposal will likely not affect private equity funds that typically invest in assets long term. However, this may disproportionately affect activist funds, which generally hold assets for one or two years. Asset managers that have investment horizons of less than three years should consider how the House Proposal will apply to their individual circumstances.

Source of Gain Upon Transfer of Partnership Interest

As held by the recent U.S. Tax Court case Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3 from July 2017, the sale of a non-“FIRPTA” partnership interest generally will not be taxable to a foreign holder, even if the partnership engages in a U.S. trade or business. We have previously written about this case, which you can read more about here.

Under the Senate Proposal, gain or loss upon such a sale generally would be treated as effectively connected with a U.S. trade or business. This provision effectively overrules Grecian Magnesite. As a result, foreign investors will likely continue to use “blocker” entities to avoid effectively connected income in the private equity context.

The House Proposal does not have any provision similar to the Senate Proposal described above.

State Pension Plans

Under current law, certain organizations are exempt from U.S. federal income tax. However, even if an organization is otherwise deemed to be exempt from U.S. federal income tax, it may still be required to pay tax on unrelated business income that is not substantially related to the performance of the organization’s tax-exempt status (commonly known as unrelated business taxable income, or “UBTI”). State and local entities (including state pension plans) that are exempt from U.S. federal income tax are not usually subject to the UBTI rules.

Under the House Proposal, all entities exempt from U.S. federal tax under Code Section 501(a), regardless of the entity’s exemption under any other provision of the Code, will be subject to the UBTI rules. This means that state and local entities that are tax exempt under both Section 501(a) and 115(1) as a government-sponsored entity will be subject to the UBTI rules. The Senate Proposal does not change current law.

Self-Employment Tax

Under current law, a limited partner’s share of income received from a partnership is excepted from self-employment tax. The initial House Proposal repealed this exception, and instead provided that a limited partner’s “labor percentage” of trade or business income is subject to self-employment tax. However, the second amendment to the House Proposal on November 9 returns to the current law. The Senate Proposal does not change current law.

Below is a summary of the Proposals and how they differ from current law:

  Current Law House Proposal Senate Proposal
Corporate Tax Rate 35% 20%, 25% for personal service corporations. 20%, effective for tax years beginning after December 31, 2018.
Individual Tax Rate Brackets at: 10%, 15%, 25%, 28%, 33%, 35% and 39.6% Brackets at: 12%, 25%, 35% and 39.6%

An additional bracket at 9% for pass-through income, phased out at certain income thresholds; phased in over five years.

Brackets at: 10%, 12%, 22.5%, 25%, 32.5%, 35% and 38.5%.
Pass-Through Tax Rate Owners of pass-through entities are taxed on income at individual rates. Certain "qualified business income" is taxed at 25%.

Remaining net business income is taxed as ordinary income.

Certain "qualified business income" is allowed a 17.4% deduction.

The deduction is limited to 50% of W-2 wages.

Interest Deductibility Businesses are allowed a full deduction for interest paid. Interest expense deduction is limited to business interest income plus 30% of adjusted taxable income before net operating loss deductions and depreciation and amortization. Interest expense deduction is limited to business interest income plus adjusted taxable income before net operating loss deductions (excluding depreciation and amortization) and 17.4% pass-through deduction.
SALT Amounts paid SALT are fully deductible. For individuals (including owners of pass-through entity), state and local income taxes are not deductible. Certain amounts of state and local property taxes are deductible.

No change for corporate deductions.

For individuals, state and local income taxes are not deductible. Certain amounts of state and local property taxes are deductible. It is unclear if this applies to the owners of a pass-through entity.

No change for corporate deductions.

Carried Interest Profits interest paid to fund managers is taxed as capital gain if investment is held for more than one year. Investments must be held for more than three years to receive capital gains treatment. No proposed change from current law.
Source of Gains The sale of a non-"FIRPTA" partnership interest generally will not be taxable to a foreign holder, even if the partnership engages in a U.S. trade or business (Grecian Magnesite). Gain or loss on the sale of a partnership interest by a foreign person will not be subject to U.S. tax. Gain or loss on the sale of a partnership interest by a foreign person will be ECI to the extent that the foreign person would have had effectively connected gain or loss had the partnership sold all of its assets.
State Pension Plans State pensions do not pay UBTI. All entities from U.S. federal tax under Section 501(a) are subject to the UBTI rules. No proposed change from current law.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Foley & Lardner LLP | Attorney Advertising

Written by:

Foley & Lardner LLP

Foley & Lardner LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.