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Pass-Through Entities Asset Management

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

DarrowEverett LLP on

The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

Fenwick & West LLP

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

Fenwick & West LLP on

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

Latham & Watkins LLP

How US Tax Reform Proposals Will Affect Private Investment Funds and Asset Managers

Latham & Watkins LLP on

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

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