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Private Equity Funds Internal Revenue Service

Alston & Bird

IRS Signals Increased Scrutiny of Deductibility of Success-Based Fees in M&A Transactions

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Our Tax Group sheds light on recent IRS rulings that disallow deductions involving success-based fees in M&A transactions. Contrary to common practice, the IRS recently ruled target companies could not deduct success-based...more

Blank Rome LLP

Private Equity and Hedge Funds Take Note: The Tax Court Says Limited Partners Must Pay Self-Employment Taxes

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In a decision that will come as potentially bad news to many private equity and hedge funds, on November 28, 2023, the U. S. Tax Court opined in Soroban Capital Partners LP versus Comm’r that limited partners in a limited...more

Skadden, Arps, Slate, Meagher & Flom LLP

Tax Court Holds Indirect Grant of Profits Interest To Be Non-Taxable, Citing IRS Guidance

On May 3, 2023, the U.S. Tax Court upheld a taxpayer’s reliance on Revenue Procedure 93-27 to characterize as a profits interest a partnership interest granted in exchange for services that were provided indirectly for the...more

Bracewell LLP

Bracewell Tax Report: April 2018 part 2

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The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Akin Gump Strauss Hauer & Feld LLP

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

Akin Gump Strauss Hauer & Feld LLP

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

Ballard Spahr LLP

Investment Management Update

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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

Foley & Lardner LLP

Partnership Tax Audit Reform and Private Funds

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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

Katten Muchin Rosenman LLP

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

Locke Lord LLP

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

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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

Lowndes

Senators Call on IRS to Finalize Management Fee Waiver Regulations

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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

McDermott Will & Emery

Focus on Private Equity - July 2015

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

Dechert LLP

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

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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

Proskauer Rose LLP

The ERISA Litigation Newsletter - May 2013

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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

Katten Muchin Rosenman LLP

IRS Delays Implementation of FATCA Tax Reporting Rules

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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