News & Analysis as of

Private Equity Funds Internal Revenue Service

Considerations for Asian Fund Managers under the U.S. New Partnership Audit Regime

The Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, resulted in a fundamental change in the way the U.S. Internal Revenue Service (IRS) will conduct audits of collective...more

Investment Management Special Report - 2017-18 Compliance Developments & Calendar for Private Fund Advisers

Introduction - Despite an anticipated de-regulatory push, there are significant new regulatory concerns for investment advisers to address in connection with their annual review of their compliance manuals....more

Investment Management Update

by Ballard Spahr LLP on

SEC Issues Guidance on Mutual Fund Fee Structure - The Securities and Exchange Commission’s (SEC) Division of Investment Management recently issued a guidance update addressing disclosure issues and certain procedural...more

Partnership Tax Audit Reform and Private Funds

by Foley & Lardner LLP on

The Bipartisan Budget Act of 2015 that was signed into law on November 2, 2015, made extensive changes to the rules that apply to partnership audits and the mechanics for collecting taxes resulting from an audit. These...more

Structuring Equity Interests for Independent Sponsors

In a traditional private equity fund, the fund managers will raise money from investors to establish a pool of capital the fund can then use to invest in a number of portfolio companies. A big benefit of a fund is that the...more

Bipartisan Budget Act of 2015 Changes Audit Rules for Private Equity and Hedge Funds

by Locke Lord LLP on

On November 2, 2015, the United States Congress enacted the Bipartisan Budget Act of 2015 (the Act) to fund the federal government. Among other provisions, the Act significantly modifies how the Internal Revenue Service (IRS)...more

Senators Call on IRS to Finalize Management Fee Waiver Regulations

Yesterday, Senators Franken, Warren, Baldwin and Whitehouse sent Treasury Secretary Lew a letter regarding management fee waiver arrangements. What is a management fee waiver arrangement? It is where a fund manager...more

IRS Proposed Tax Regulations Aimed at Fee Waiver Arrangements

by DLA Piper on

The Treasury Department and the Internal Revenue Service have issued proposed regulations addressing disguised payment for services of a partner, including the proper tax treatment of fee waiver arrangements commonly used by...more

Focus on Private Equity - July 2015

by McDermott Will & Emery on

What Private Equity Funds Should Know About ERISA: Basics of ERISA Coverage - The Employee Retirement Income Security Act of 1974, as amended (ERISA) imposes numerous duties on fiduciaries holding employee benefit...more

An Appreciation for Hedging Your Bets on Deferred Compensation: IRS Issues Revenue Ruling 2014-18 Under Section 457A of the...

by Dechert LLP on

Under Section 457A of the Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those entities....more

Operational Regulatory Risks Facing Private Equity Firms

by Reed Smith on

If you work in the private equity world, you probably know that you are already exposed to a variety of regulatory risks and obligations that can have a significant impact on your firm’s operations and financial rate of...more

The ERISA Litigation Newsletter - May 2013

by Proskauer Rose LLP on

This month our articles focus on the availability of damages in complex ERISA class actions and withdrawal liability actions. Jackie Len first provides Proskauer's perspective on the implications for ERISA litigation arising...more

IRS Delays Implementation of FATCA Tax Reporting Rules

by Katten Muchin Rosenman LLP on

The Internal Revenue Service this week released Announcement 2012-42 (the Announcement), which postpones until 2014 the need for foreign hedge funds and private equity funds to request Foreign Account Tax Compliance Act...more

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