In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more
1/31/2025
/ Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Private Equity Funds ,
Private Funds ,
Regulatory Requirements ,
Tax Court ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Reform ,
U.S. Treasury
The recently proposed regulations, if finalized, would govern the treatment of RICs’ income inclusions in respect of CFCs and PFICs for purposes of the income test applicable to RICs; in related guidance, the IRS also...more
IRS Notice postpones several key deadlines and provides other relief.
On September 18, the US Internal Revenue Service (IRS) released Notice 2015-66 (the Notice) announcing that the US Department of the Treasury and the...more
9/28/2015
/ Amended Regulation ,
FATCA ,
FATCA Timeline ,
Foreign Financial Institutions (FFI) ,
Global Intermediary Identification Number (GIIN) ,
Grandfathered Obligations ,
Intergovernmental Agreements ,
IRS ,
Pro Rata Allocation Rule ,
U.S. Treasury ,
Withholding Requirements