Owning an NFL team is no longer a fantasy. The National Football League (the “NFL” or the “League”) voted to allow minority stakes to be sold to private equity firms (“PE”). However, according to NFL.com, “an executive from...more
EXECUTIVE SUMMARY - Private equity structures often use “blockers” to achieve certain tax benefits. In this Legal Update, we explain what blockers are, how they may be used in a subscription credit facility, and what...more
This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. assets utilizing leveraged blockers and other tax planning...more
A key initial decision for a manager launching a new hedge fund is to decide between: A “master-feeder” fund structure: In a typical “master-feeder” structure, an onshore “feeder” fund and an offshore “feeder” fund both...more
Different hedge fund investors have different tax concerns that must be taken into account when structuring a hedge fund and its portfolio investments. Hedge fund investors generally fall into three categories:...more
On January 19, 2024, the US Small Business Administration (SBA) created a new exception applicable to business development companies (BDCs) with wholly owned small business investment companies (SBICs) that will allow use of...more
Blocker entities are a common part of private equity fund structures. In many cases, blockers are used to insulate foreign and tax-exempt investors from direct tax liability in the fund’s home jurisdiction. Blockers are...more
• 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
Following a series of delays, on August 18 the U.S. Small Business Administration (SBA) announced that it would withdraw the Final Rule modifying its regulations on the ability of a small business investment company (SBIC) to...more
New SBA rule affects the holding company and the blocker corporation exceptions for SBICs’ financing passive businesses. On December 28, the U.S. Small Business Administration (SBA) released a Final Rule modifying its...more
On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more
On Wednesday, September 28, the IRS and Treasury Department proposed regulations under Section 851 of the Code that, if finalized, could prospectively invalidate dozens of private letter rulings treating subpart F and passive...more
Overview - Large institutional investors including pension plans and endowments and foundations have made significant investments in timberland over the last forty years. These same investors have also made significant...more
For some time now legislative bodies have been discussing the implementation of rules according to which the acquisition of “economic” (wirtschaftliche) participating interests of more than 95 % on a consolidated basis in a...more
Originally Published in The Legal Special 2013 - A Private Equity International Supplement on April 1, 2013. Interest in co-investment rights has spiked recently as institutional and other fund investors have sought to...more