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Private Equity Tax Liability

Skadden, Arps, Slate, Meagher & Flom LLP

Newly Proposed Regulations on Stock Buyback Excise Tax Largely Adopt Approach From Initial IRS Guidance

On April 12, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations (89 FR 25980 and 89 FR 25829) on the excise tax on stock buybacks enacted as part of the Inflation Reduction...more

Troutman Pepper

Rolling Over and Section 704(c); What’s the Big Deal? — Part 4: The Remedial Method

Troutman Pepper on

In our continuing series on Section 704(c) of the Internal Revenue Code (the Code) we discuss the application of the remedial method to correct for distortions caused by the ceiling rule. As previously discussed, when the tax...more

Troutman Pepper

Rolling Over and Section 704(c); What's the Big Deal? — Part 3: The Traditional Method With Curative Allocations

Troutman Pepper on

Continuing with our series on the implications of the application of Section 704(c), the below discussion addresses the use of the traditional method with curative allocations. In Part 1 [insert link] we gave a broad overview...more

Troutman Pepper

Rolling Over and Section 704(c); What's the Big Deal? — Part 2: The Traditional Method

Troutman Pepper on

In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner. As...more

Troutman Pepper

What We're Seeing – 2022 Dealmaking Outlook

Troutman Pepper on

The Rearview Mirror - Robust multiples and fear that the Biden administration might succeed in passing tax laws resulted in 2021 being one of the busiest years ever in the private equity space. Within the capital markets,...more

Jones Day

2021 Transactional Year in Review and 2022 Forecast: Until Enacted or Withdrawn, Proposed U.S. Tax Reform Continues to Have an...

Jones Day on

Since early 2021, Congress has been working on legislation that would alter the U.S. tax laws and potentially have a significant impact on M&A and private equity transactions....more

Stikeman Elliott LLP

Private Equity - Recent Developments Of Importance

Stikeman Elliott LLP on

The first nine months of 2021 set records for global M&A activity and kept private equity firms especially busy. An abundance of dry powder and low interest rates have encouraged private equity investors to make up for lost...more

Rivkin Radler LLP

New York’s Pass-Through Entity Tax, F Reorgs, and the Sale of An Electing S Corp

Rivkin Radler LLP on

Timing- I had planned to post this piece during the third week of December, a day or so after the exchange between Senator Manchin and the White House sealed the fate of the Build Back Better plan, at least in its current...more

Goodwin

Minority Investments In Asset Managers

Goodwin on

Over the years, we have represented a number of investors, target companies and management teams in minority transactions. The market for “GP stakes” and similar non-controlling transactions with asset managers has grown...more

Proskauer - Tax Talks

High Court decision highlights importance of ensuring claims notices include required information

Proskauer - Tax Talks on

In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers’ argument that a notice of a tax claim under a tax covenant served on them by the buyer was invalid because it did not...more

Proskauer Rose LLP

UK Tax Round Up - December 2019

Proskauer Rose LLP on

UK Case Developments - IR35 – no mutuality of obligation to create a contract of employment - RALC Consulting Ltd v HMRC has provided the First-tier Tribunal (FTT) with another opportunity to consider the application...more

Dechert LLP

Global Private Equity Newsletter - Winter 2019 Edition: U.S. Carve-Out Transactions: A Fertile Ground for Private Equity Firms

Dechert LLP on

Driven by the influence of shareholders, activists and competitive market forces, public companies are demonstrating renewed focus on their core businesses. Reductions in the U.S. corporate tax rate from 35% to 21% have...more

Skadden, Arps, Slate, Meagher & Flom LLP

"No Gains, Just Pain: Increasingly Uncomfortable Taxation Environment for Private Equity Executives’ Compensation"

Arguing that their compensation should count as capital gains — since it derives from the appreciation in value of portfolio companies — private equity executives in Europe generally have been taxed under the more favorable...more

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