News & Analysis as of September 22, 2024

Asset Management

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Tax Court holds that an offshore fund is engaged in a U.S. trade or business

Proskauer - Tax Talks on 1/3/2024

On November 15, 2023, the U.S. Tax Court held in YA Global Investments v. Commissioner that a non-U.S. private equity fund (YA Global) with a U.S. asset manager that bought equity and convertible debt of U.S. portfolio...more

Top Tax and Legal Considerations for Wealthy Families Going Global

Greenberg Glusker LLP on 10/5/2023

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

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on 10/3/2023

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

International News: Spotlight on Tax

McDermott Will & Emery on 5/5/2022

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

What is a Trust?

Freeman Law on 2/9/2022

Trusts - Trusts play an important role in estate and tax planning. A trust is a fiduciary arrangement that allows a trustee to hold legal title to assets for the benefit of a beneficiary. The beneficiary is, in turn, said...more

Selling Assets to Reduce Your Estate Tax Exposure - Act Before September 30

Steptoe & Johnson PLLC on 9/17/2020

If you have an estate that may be subject to estate tax next year, particularly if the November election results in a greatly reduced federal estate tax exemption in 2021, now is the time to remove assets from your taxable...more

Opportunity Zone Funds – Part IV: The Second Round of Proposed Regulations

Foster Garvey PC on 4/24/2019

On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more

U.S. Withholding Tax and Reporting Action Items for Investment Funds and Asset Managers (Fall 2018)

Akin Gump Strauss Hauer & Feld LLP on 10/8/2018

• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more

Tax Reform and Estate Planning: How the 2017 Tax Cuts and Jobs Act Impacts Estate Plans for McNair Clients

Burr & Forman on 10/5/2018

When the 2017 Tax Cuts and Jobs Act was passed, significant changes were made to the Federal Estate, Gift and Generation-Skipping Transfer Tax, the most prominent of which is the increased applicable exclusion amount, which...more

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

Fenwick & West LLP on 9/18/2018

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

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