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Asset Management Tax Liability

Mayer Brown

Déductibilité fiscale de services d’asset management rendus entre sociétés liées

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La Cour administrative d’appel de Paris confirme que la déductibilité fiscale de charges facturées au titre d’un contrat d’asset management entre sociétés liées suppose la démonstration concrète de prestations réellement...more

DLA Piper

Key Updates to the House Committee on Ways and Means’ Proposed Tax Bill

DLA Piper on

On May 12, 2025, the House Committee on Ways and Means Chairman Jason Smith (R-MO) released an amended 389-page bill, entitled “The One, Big, Beautiful Bill,” and the staff of the Joint Committee on Taxation released a...more

Ropes & Gray LLP

Impact of Permanent Establishment Reform for Credit Funds

Ropes & Gray LLP on

On 28 April, the UK Government produced draft legislation for consultation as the latest step in the reform of UK rules on transfer pricing, permanent establishments and diverted profits tax. From an asset management...more

Walkers

Retiring trustee – reasonable security and retention of assets

Walkers on

Under section 43(b) of the Trusts (Guernsey) Law, 2007, when a trustee resigns or is removed it may require that it be provided with reasonable security for liabilities before surrendering trust property....more

Falcon Rappaport & Berkman LLP

Shielding Your Cryptocurrency: Essential Estate Planning and Asset Protection Strategies in the Digital Age

As cryptocurrencies like Bitcoin surge to unprecedented values—crossing the $100,000 mark at the time of this writing—both seasoned investors and newcomers are pouring billions into this thriving asset class. The U.S....more

Gray Reed

Federal Income Taxation of Intellectual Property Development and Cost Recovery

Gray Reed on

Intellectual property (“IP”) development can cost millions of dollars so cost recovery timing can be financially material. General tax principles typically require that expenses associated with creating assets having useful...more

Greenberg Glusker LLP

Top Tax and Legal Considerations for Wealthy Families Going Global

Greenberg Glusker LLP on

In recent years, we have seen high net-worth and ultra-high-net-worth families become, increasingly, “global citizens.” As families and their assets touch multiple jurisdictions, a myriad of issues become especially important...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

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Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Cadwalader, Wickersham & Taft LLP

Limited Partner Exception Challenged by Hedge Fund Legend

An investment management firm founded and owned by legendary investor (and New York Mets owner) Steve Cohen on August 11 filed a petition in Tax Court contesting an IRS audit adjustment in the amount of $344,063,484 for tax...more

ASKramer Law

Taxation of Derivatives Held by Investors: What to Know

ASKramer Law on

The taxation of derivatives and financial products has developed in an uncoordinated and piecemeal fashion. Tax rules have largely been enacted in response to what the government has perceived as abusive transactions —...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

Freeman Law

Why You Should Hire a Tax Professional to Review Your Trust

Freeman Law on

Trusts come in many variations, rendering them often difficult for non-attorneys to follow and comprehend.  Indeed, this variation can often be seen in the nomenclature used for trust arrangements, which includes terms such...more

Proskauer - Tax Talks

BlueCrest FTT Decision –  Salaried Member Rules and Asset Managers

Proskauer - Tax Talks on

The recent decision of the First-tier Tribunal (FTT) in BlueCrest Capital Management (UK) LLP v HMRC (29 June 2022) is the first time the UK’s salaried member rules (the Rules) have been considered in the context of an asset...more

Goodwin

Minority Investments In Asset Managers

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Over the years, we have represented a number of investors, target companies and management teams in minority transactions. The market for “GP stakes” and similar non-controlling transactions with asset managers has grown...more

BakerHostetler

State Tax in Transactions - Expanding Nexus Footprint (Part II)

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M&A transactions can have big implications for your company's nexus footprint. In part two of the series on M&A transactions, Matt Hunsaker breaks down nexus issues that should be on your radar if your company is engaging in...more

McDermott Will & Emery

[Event] 2019 Tax In The City®: Seattle - October 24th, Seattle, WA

McDermott Will & Emery on

We invite you to join us for a discussion on current tax issues including: • Judicial deference and potential impact on TCJA audits • Developments and planning considerations for intangible assets o US tax...more

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