Welcome to the November 2024 edition of our UK Tax Round Up. This month has seen publication of the Finance Bill 2024-25 and interesting cases on the loan relationship unallowable purpose test and the extent that tax applies...more
On October 10, Representative Matt Cartwright (D-PA) introduced the Bill Pascrell Ending Tax Giveaway Act with the goal of “closing the controversial carried interest loophole.”...more
On Wednesday 30 October 2024, the UK government announced changes to the UK taxation of carried interest as part of the 2024 Autumn Budget. Changes were expected following statements made by the Labour Party in the run up to...more
The Chancellor’s announcement on Wednesday that the UK’s capital gains tax (CGT) rate for carried interest would be increased by only a few percentage points from 28% to 32%, effective April 2025, was welcome news to many....more
Rachel Reeves, the first female Chancellor of the Exchequer in the role’s 800-year history, delivered Labour’s first budget in 14 years on the 30th October. We have set out below a brief summary of some of the tax measures...more
Yesterday, 30 October 2024, the Chancellor announced that the Autumn 2024 budget will raise taxes by £40bn, the biggest raise since 1993. While the Autumn budget arguably does not portray as pessimistic an outlook for...more
The real estate sector was not ignored by Budget announcements today. There were no seismic changes – the changes announced were less impactful than the speculation in the weeks preceding the Budget....more
Welcome to the July edition of the UK Tax Round Up. This month features a call for evidence from the government on potential changes to the tax on carried interest and interesting decisions on the application of the carried...more
Recent publicity around the UK taxation of carried interest may, in due course, make it more likely that a UK government would look again at the tax rules around carried interest. ...more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023. The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more
On July 27, 2022, Senator Joe Manchin and Senate Majority Leader Chuck Schumer announced that they have reached an agreement on a budget reconciliation bill (the Inflation Reduction Act of 2022, the “Act”). Although the Act...more
OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more
US Senators Joe Manchin and Chuck Schumer announced on July 27 an agreement in principle on a legislative proposal, known as the Inflation Reduction Act of 2022, that includes a range of measures addressing consumer energy...more
Senators Manchin and Schumer this week announced that the “Inflation Reduction Act of 2022” will be added to the FY2022 Budget Reconciliation bill. The bill includes changes to Section 1061 of the Code (which was added to the...more
Hedge Funds and Taxes - Hedge funds provide a vehicle to pool private capital for investment in stocks, securities and financial derivatives. While hedge funds take on many different structures—including master-feeder,...more
...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more
I. Introduction - On September 15, 2021, the House Ways and Means Committee approved tax provisions for proposed inclusion in the Build Back Better Act (the BBBA). If enacted in their current form, the proposals would,...more
In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. On May 28, 2021, the United State Department of Treasury issued a report entitled “General Explanation of...more
In January 2021, the U.S. Department of Treasury and the Internal Revenue Service released final regulations (the Final Regulations) under Section 1061 of the Internal Revenue Code of 1986, as amended (the Code). Code...more
On August 5, 2021, U.S. Senate Finance Committee Chair Ron Wyden (D-Ore.) and Senator Sheldon Whitehouse (D-R.I.) introduced legislation that, if enacted, would tax carried interest recipients annually at ordinary interest...more
President Biden has proposed major changes to the Federal tax laws, some of which are sought to be effective earlier in 2021 (i.e., we are already operating under these changes, if they later become adopted), as compared to...more
Following the enactment last year of the Limited Partnership Fund Ordinance, which has seen strong take up in its first eight months of operation, the new tax concession on carried interest earned from the activities of...more
On April 28, 2021, the White House issued a fact sheet which set forth some additional details on the tax increase proposals contained in President Biden’s “American Families Plan.” ...more
On April 28, 2021, in an address to a Joint Session of Congress and a Fact Sheet published by the White House, President Biden introduced the “American Families Plan,” the President’s plan for spending and a series of tax...more
The American Jobs Plan is a $2 trillion plan to repair and revitalize America’s infrastructure. The plan includes: $115 billion to repair bridges, highways, roads and other transit systems...more