The Preferred Return Podcast | AIFMD II – Implementation Begins
JONES DAY TALKS®: Corporate Venture Capital: Market Overview, Trends in Deal Terms, and Special Considerations
A 2024 Economic Outlook - Troutman Pepper Podcast
Business Better Podcast Episode: Investing in Consumer Brands – A Conversation with SBJ Capital
New SEC Private Funds Rules – What Is Happening and What You Need to Know - Troutman Pepper Podcast
PLI's inSecurities Podcast - Alternative Asset Managers in the Crosshairs
Cornerstone Research Experts in Focus: Jules van Binsbergen
International News Spotlight on Private Equity and Private Wealth with Merrick White
Nota Bene Episode 111: Charting the New World of Music Royalty Investment with Sid Fohrman
Digital Health Trends Shaping 2021: Prioritizing Diversity & Striving for Greater Representation
2020: An Unprecedented Year for Digital Health
Nota Bene Episode 106: The Corporate Investor Movement Toward Environmental, Social, and Governmental Policies with Allison Troianos and Ariel Yehezkel
Dark Side of the Moon
Investment Management and Private Funds Roundtable: TALF 2020 and PPP Update
With a Little Help from My Friends
Videocast: Asset management regulation in 2020 videocast series – SEC enforcement
Viewpoints: Portfolio Company Pension Liabilities
Videocast: Asset management regulation in 2020 videocast series – Investment company developments
Investment Management Roundtable Discussion – Data Privacy and Security
Investment Management Roundtable Discussion – Regulatory and Enforcement Update
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
Politicians are touting a new tax proposal they claim would "close the carried interest loophole." The tax proposal wouldn't eliminate carried interests as implied—it would only extend the holding period from three to five...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
Earlier this year, the Hong Kong government introduced the Inland Revenue (Amendment) (Tax Concessions for Carried Interest) Bill 2021 which drew much attention from the global private equity market. On 7 May 2021, the...more
While the final regulations simplify key exceptions and contain favorable changes, ambiguity continues for investment fund managers. On January 7, 2021, the US Treasury Department and Internal Revenue Service (together,...more
We are often asked about the prevalent market options for structuring carried interest provisions in venture capital funds. In this post, we’ll speak of mainstream venture capital funds, so to speak. Terms differ in special...more
The U.S. Department of Treasury published Final Regulations for the Qualified Opportunity Zone (QOZ) program on January 13, 2020, which answer many, but not all, of the questions arising from the Proposed Regulations released...more
Massachusetts Senator and presidential hopeful Elizabeth Warren released perhaps the most ambitious plan the country has ever seen with respect to regulation of the private equity and investment fund industry. She released...more
Qualified Opportunity Funds - The Opportunity Zone tax incentive program allows taxpayers that invest in a Qualified Opportunity Fund to (i) defer paying taxes on the capital gain from the sale or exchange of appreciated...more
• The latest set of proposed opportunity zone (OZ) regulations (the “2019 proposed regulations”) provide much-needed flexibility with regard to qualified opportunity funds (“OZ Funds”) and expand the types of businesses and...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
Aspects of the current proposals could significantly alter the US taxation of investment funds, sponsors, and investors. Key Points: ..Major changes to US tax laws on business tax rates, interest deductibility, and...more
• 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
After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more
According to a recent BNA news report, the Internal Revenue Service (IRS) has proposed adjustments and penalties to a private fund manager related to its use of management fee waivers and transaction fee offsets. Based on the...more
The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more
The Belgian Stock Option Law sets out the tax treatment of stock options, thereby eliminating the uncertainty as to the taxable value of the stock options. In the past, the Belgian Ruling Commission has been reluctant to...more
A bill recently introduced in the New York State Assembly would impose additional tax on carried interest. The taxation of carried interest has been widely discussed over the last decade, with a number of bills introduced...more
The UK Government, as anticipated, issued draft legislation on 9 December designed to establish clear rules as to when carried interest can qualify for favourable capital gains tax treatment. The draft legislation follows a...more
Last week, I was at the ABA Tax Section meeting in Chicago. During one of the partnership panels, Clifford Warren, Special Counsel to the Associate Chief Counsel (Passthroughs and Special Industries) at the IRS, was posed...more
Tax Proposals in Summer 2015 Budget to Affect UK Asset Managers - The UK Summer Budget was announced on 8 July 2015, and included a number of unexpected tax proposals affecting the UK asset management industry, including...more
In This Issue: - SEC Announces First-of-Its-Kind Whistleblower Award To an Audit and Compliance Professional - SEC Issues No-Action Letter To Allow for Amendment of a Sub-Advisory Agreement without Shareholder...more