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Investment Funds Business Taxes

BCLP

Impact of UK Autumn Budget on real estate sector

BCLP on

It was a relatively light Budget for the real estate sector. Highlights included the long-awaited announcement of the rate of the residential property developer tax and some reform of business rates....more

International Lawyers Network

Establishing A Business Entity In Liechtenstein (Updated)

The Principality of Liechtenstein lies at the centre of Europe, nestled between Switzerland and Austria, next to the river Rhine. The form of government is a constitutional monarchy established on democratic parliamentary...more

International Lawyers Network

Establishing A Business Entity In Liechtenstein

The Principality of Liechtenstein lies at the centre of Europe, nestled between Switzerland and Austria, next to the river Rhine. The form of government is a constitutional monarchy established on democratic parliamentary...more

Dechert LLP

IRS Issues Regulations Clarifying Opportunity Zones and Opportunity Funds

Dechert LLP on

The Opportunity Zone program created by the Tax Cuts and Jobs Act of 2017 (the “TCJA”) allows taxpayers that realize certain gains to elect to defer the federal income tax on such gains by reinvesting them into Qualified...more

Lowndes

Tax Cut and Jobs Act Limits Benefit of Carried Interest

Lowndes on

After many years of being the target of Congress and the IRS, the Tax Cut and Jobs Act finally succeeded in limiting the beneficial tax treatment of carried interests, at least for some taxpayers. This change will be of...more

Akin Gump Strauss Hauer & Feld LLP

Top 10 Topics for Directors in 2018

EXECUTIVE SUMMARY - 1. Cybersecurity threats. Cybersecurity preparedness is essential in 2018 as the risk of, and associated adverse impact of, breaches continue to rise. The past year redefined the upward bounds of the...more

Akin Gump Strauss Hauer & Feld LLP

Carried Interest and Other Tax Reform Highlights for Investment Funds and Asset Managers

• 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

Skadden, Arps, Slate, Meagher & Flom LLP

"Recent Court of Appeals Decision Provides Hope for Taxpayers Fighting for Congressionally Sanctioned Tax Benefits"

For the second time in just over a year, the U.S. Court of Appeals for the Sixth Circuit reversed the United States Tax Court and affirmed the right of a taxpayer to structure its affairs in a manner that takes into account...more

Farrell Fritz, P.C.

When Investing In A Partnership May Be A Tax Problem

Farrell Fritz, P.C. on

A business entity that is treated as a “flow-through” for income tax purposes enjoys the benefit of a single level of tax – the entity itself is typically not subject to tax on its net income; rather, that income “flows...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS and Treasury Issue Final Debt/Equity Regulations"

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

Dechert LLP

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Dechert LLP on

Tax: HMRC Publishes Filing Dates for New AIFM Mechanism for Partnership Deferred Remuneration Arrangements - The Finance Act 2014 introduced a provision intended to help partnerships (including LLPs) that are AIFM...more

Goulston & Storrs PC

IRS Treats U.S. Fund Manager as Agent of Foreign Investor – Subjecting Investor to US Trade or Business Taxation

Goulston & Storrs PC on

In CCA 201501013, the IRS found that an offshore fund making loans to U.S. borrowers was engaged in a U.S. trade or business where multiple loans owned by the fund were originated by an agent of the fund. This conclusion is...more

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