News & Analysis as of

Internal Revenue Code (IRC) Private Equity Funds

McDermott Will & Emery

Lawmakers Revisit Tax Treatment of Carried Interest

McDermott Will & Emery on

The tax treatment of carried interest has long been a subject of political debate. Since 2007, almost annually, the taxation of carried interest has found its way into either proposed legislation or presidential budget...more

Morgan Lewis

Private Funds Year in Review: Key Tax Developments That Shaped the Industry in 2024

Morgan Lewis on

In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more

Blank Rome LLP

Private Equity and Hedge Funds Take Note: The Tax Court Says Limited Partners Must Pay Self-Employment Taxes

Blank Rome LLP on

In a decision that will come as potentially bad news to many private equity and hedge funds, on November 28, 2023, the U. S. Tax Court opined in Soroban Capital Partners LP versus Comm’r that limited partners in a limited...more

Robinson Bradshaw

280G Considerations for Portfolio Company Exits

Robinson Bradshaw on

Intro Portfolio companies of venture capital and private equity funds usually motivate key executives through compensation tied to performance upon an exit. Such structures align the incentives of the fund with those of the...more

Freeman Law

Hedge Funds 101: An Introduction to Tax Issues

Freeman Law on

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

Mintz - Employment, Labor & Benefits...

Private Equity Funds, Controlled Groups, and Multi-Employer Plan Withdrawal Liability: The Lessons of Sun Capital Partners vs. New...

Both the Internal Revenue Code (the “Code”) and the Employee Retirement Income Security Act (“ERISA”) contain rules that aggregate trades and businesses under common control. For the most part, these rules are intended to...more

McCarter & English, LLP

Private Equity Funds Liable for Portfolio Company's Pension Obligations

A U.S. District Court issued a ruling on March 28 that affects pension liabilities for private equity funds and their portfolio companies. Taken further, the ruling potentially changes fundamental rules for tax-qualified...more

Troutman Pepper

Private Equity Fees and Expenses

Troutman Pepper on

In This Presentation: - Agenda - Typical Fund Structure - Typical Fund Waterfall - Fund Economics- Nuances - LPA Provisions - Fund Due Diligence - Legal Landscape - PEI...more

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