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Investment Funds Internal Revenue Service Fund Managers

Tannenbaum Helpern Syracuse & Hirschtritt LLP

Investment Fund Manager Update on Self-Employment Limited Partner Exception: Tax Court Holds that Limited Partners May Be Subject...

On November 28, 2023, the Tax Court held that limited partners in state law limited partnerships cannot automatically rely on Section 1402(a)(13) of the Self-Employment Contributions Act (“SECA”) to exclude their distributive...more

Seward & Kissel LLP

For Fund Managers, Tax Court Ruling Sets Limited Partners Back “As Such”

Seward & Kissel LLP on

Memorandum to our Investment Management Clients and Friends - The United States Tax Court recently issued a ruling (the “Ruling”) pertaining to the possible exclusion of a limited partner’s distributive share of income...more

Polsinelli

No S-Corp for You? – New Proposed Carried Interest Regulations that May Affect Crypto Fund Managers

Polsinelli on

Historically, the ability for investment fund managers to take profits in the form of carried interest has allowed those managers to pay the lower long-term capital gains tax rate (compared to income) so long as the...more

Orrick, Herrington & Sutcliffe LLP

Final Tax Regulations Offer More Certainty to Opportunity Zone Fund Managers and Investors

Opportunity Zone (or “OZ”) investment was hailed in 2018 and 2019 as the hottest and most innovative way of attracting significant private capital to distressed communities in the United States and its territories by offering...more

Akin Gump Strauss Hauer & Feld LLP

Opportunity Zones: How Communities Can Leverage This New Provision to Jumpstart Investment

• Even though practitioners are awaiting proposed regulations on the new opportunity zone provision, interested parties are already starting to set up qualified opportunity funds to pool investor capital. • States, cities,...more

Dorsey & Whitney LLP

Tax Law Changes Compel Amendments to Investment Fund Agreements

Dorsey & Whitney LLP on

Significant changes in federal income tax laws may require existing private investment fund agreements to be amended prior to the end of the 2018 calendar year. Investment managers should consult with their fund counsel to...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS Proposes Regulations Addressing Profits Interests, Investment Fund Fee Waiver Arrangements"

On July 23, 2015, the Internal Revenue Service (IRS) and the Treasury Department proposed regulations that address the tax treatment of certain partnership interests issued in exchange for services. Of particular note, the...more

Foley Hoag LLP

FATCA Compliance for Investment Fund Managers, Part Three

Foley Hoag LLP on

Offshore Master with U.S. and Offshore Feeders - This is the third in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect...more

Foley Hoag LLP

FATCA Compliance for Investment Fund Managers Part One

Foley Hoag LLP on

U.S. Funds with Only U.S. Investors - FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more

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