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Asset Management Corporate Taxes

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

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The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

ASKramer Law

Business Taxation of Hedging Transactions Part II: Common Situations

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What is the “tax character” of a hedge? A taxpayer receives ordinary gain or loss on qualified hedges that have been properly identified in accordance with Treasury Regulation § 1.1221-2. This allows a taxpayer to ensure that...more

Akin Gump Strauss Hauer & Feld LLP

UK Spring Budget 2023: Points for Asset Managers

Introduction - On 15 March 2023, the UK government revealed the widely anticipated Spring Budget, which contained a number of measures that may be of interest to asset managers....more

Gerald Nowotny - Law Office of Gerald R....

How Can I Tell You – Part II

In my last installment, I introduced you to the best singer you've never heard of - Lani Hall. She made her fame singing in Portuguese (Sergio Mendes and Brasil 66) and Spanish (beautifully I might add!) while being unable to...more

Akin Gump Strauss Hauer & Feld LLP

UK Mini-Budget - Helpful for Asset Managers

The government’s 2022 Growth Plan, deceptively referred to as the “mini-budget,” has brought in notable changes likely to impact the funds industry. In particular, a number of the changes will help ensure the continued...more

McDermott Will & Emery

International News: Spotlight on Tax

INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more

Goulston & Storrs PC

Carried Interest & Deductibility: What is the Best Option for Your Family Office Structure?

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Should a family office asset manager receive a carried interest from the family investment vehicles it manages? If yes, how does the carried interest align with the intergenerational planning of the family office?...more

Dechert LLP

COVID-19: UK Tax Residence Risks for Offshore Funds and Related Entities

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Non-UK resident companies play a variety of roles in fund structures managed by UK based asset managers. They are commonly used as the fund vehicle itself, as the general partner of a limited partnership fund vehicle, and/or...more

Dechert LLP

"No Deal" Brexit Risk Grows

Dechert LLP on

The UK House of Commons has rejected the government’s proposed Withdrawal Agreement. Unless the Agreement (or an amended version of it) is approved by the House of Commons, or the Brexit date of 29 March 2019 is postponed or...more

Dechert LLP

Financial Services Quarterly Report - Third Quarter 2018: Hong Kong Facilitates Market Development by Introducing Open-Ended Fund...

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Hong Kong is increasingly a popular jurisdiction for fund distribution, given its nexus with the People’s Republic of China. Historically, investment funds usually have been established in the form of offshore mutual funds,...more

Fenwick & West LLP

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

Dechert LLP

Investment Funds Update Europe - Legal and regulatory updates for the funds industry from the key asset management centres and...

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Consultation Paper: amendments to Central Bank UCITS Regulations - The Central Bank published a Consultation Paper (CP 119) on 29 March 2018, proposing amendments to the Central Bank UCITS Regulations and the consolidation...more

Dechert LLP

Asset Management Regulatory Roundup - April 2018 - Issue 7

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A compact summary of the most recent regulatory developments relevant to the UK asset management industry. This issue includes details of the FCA’s statement on the implementation period for Brexit; the requirement for firms...more

Akin Gump Strauss Hauer & Feld LLP

Carried Interest and Other Tax Reform Highlights for Investment Funds and Asset Managers

• 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

Proskauer Rose LLP

Tax Round Up - April 2017

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Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

Akin Gump Strauss Hauer & Feld LLP

UK Summer Budget 2015

On Wednesday, 8 July 2015, George Osborne delivered the UK Summer Budget. The first Budget of the new Conservative government (and the second Budget of 2015), the Summer Budget is wide-ranging in scope and potentially...more

Akin Gump Strauss Hauer & Feld LLP

UK Budget 2015: Key Implications for Alternative Asset Managers

In a speech crammed full of digs aimed at opposition parties (and the French), the UK’s Chancellor of the Exchequer delivered his final pre-election Budget this afternoon....more

Morgan Lewis

Tax Measures in 2013 UK Budget

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UK government supports businesses, focusing on the UK's competitiveness while clamping down on tax avoidance and evasion. On 20 March, UK Chancellor of the Exchequer George Osborne released the UK's 2013 budget. The...more

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