NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Assets Under Management (AUM)!
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Asset Under Management (AUM)!
THE WONDER YEARS WEBINAR
Roetzel HealthLaw HotSpot: Optimizing Your Practice for Sale
Qualified Opportunity Zone Update: Highlights of Treasury's Second Set of Proposed Regulations
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Qualified Opportunity Zone Fund Investments
Episode 26: Talking Tax Reform and Executive Comp
Executive Compensation Packages – Interview with David Lagasse, Member, Mintz Levin
What Individuals and Businesses Need to Know About the American Taxpayer Relief Act
Just over a week ago, in Changes to Tax on Carried Interest Would Lead to Conflicts of Interest, I wrote about a proposal in Congress to modify the tax laws relating to carried interests. However, now like Ko-Ko, carried...more
On July 27, 2022, Senate Majority Leader Chuck Schumer and Senator Joe Manchin announced their agreement on proposed legislation (the “Inflation Reduction Act of 2022” or “Act”) that is expected to be considered by the Senate...more
Investment, private equity, and real estate fund managers should consider becoming familiar with the complex final regulations on the preferential tax treatment of “carried interest” under Section 1061 of the Internal Revenue...more
On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more
On July 31, 2020, the U.S. Internal Revenue Service (the "IRS") and the U.S. Treasury Department ("Treasury") issued proposed regulations (the "Proposed Regulations") that provide taxpayers with definitional and computational...more
The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) on July 31, 2020 issued long-awaited proposed regulations (the “Proposed Regulations”) providing guidance under section 1061...more
Opportunity Zone (or “OZ”) investment was hailed in 2018 and 2019 as the hottest and most innovative way of attracting significant private capital to distressed communities in the United States and its territories by offering...more
Imagine you are a professional musician who is building a performance career. You hire an artist manager to promote you, obtain performance gigs, and to negotiate contracts for your gigs for a period of five years. Your...more
• Individuals that are UK tax resident and non-UK domiciled have the ability until 5 April 2019 to cleanse their mixed overseas funds and accounts. • Affected individuals should act now to review their position and assess...more
New development: The IRS has issued guidance that the exception to the new 3-year hold requirement for carried interests held by “corporations” does not apply to S corporations. As previously discussed, the 2017 Tax Cuts...more
Prior to the passage of the Tax Cuts and Jobs Act (the “Act”), one of the more controversial and hotly-debated tax benefits was the so-called “carried interest,” which allowed certain fund managers and venture capital firms...more
The 2017 Tax Cuts and Jobs Act (the Act), signed by President Trump last month, significantly affects the ability of the managers of investment funds to receive long-term capital gains with respect to their carried interest....more
Effective immediately, there is a new requirement that each particular portfolio company interest which is the subject of a disposition event needs to have been held by the fund for more than 3 years in order for the...more
The management packages offered to managers in LBOs can sometimes be differentiating factors for financial sponsors enabling them to win a competitive process for the acquisition of a target company. However, although...more
On February 9th, President Obama released his Budget Proposals for 2017 (the "Budget Proposals"). The Budget Proposals include the following proposals that may affect private investment fund managers...more
Further to our client alert in July this year, the UK Government recently proposed further changes to the UK taxation of carried interest and disguised investment management fees (DIMF). The UK Government proposed...more
Yesterday, Senators Franken, Warren, Baldwin and Whitehouse sent Treasury Secretary Lew a letter regarding management fee waiver arrangements. What is a management fee waiver arrangement? It is where a fund manager...more
On July 22, 2015, the U.S. Department of the Treasury and U.S. Internal Revenue Service issued proposed Treasury Regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended, addressing management...more
Overview - The issue of carried interest taxation as obscure an issue as it is, has gotten all kinds of attention in the media over the last several years. Most recently, the issue garnered national attention during...more