This Memorandum continues our analysis of the current U.S. federal tax reform process. Today, the House of Representative passed the Senate’s version of the One Big, Beautiful Bill (the “Senate Tax Bill”). The Senate Tax Bill...more
On February 6, 2025, Democratic Senators and Representatives proposed the Carried Interest Fairness Act, which would treat carried interest as ordinary income. Additionally, on the same day President Trump met with...more
2/11/2025
/ Capital Gains ,
Carried Interest ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
Investment Funds ,
IRS ,
Private Equity ,
Tax Credits ,
Tax Liability ,
Tax Planning ,
Tax Reform
The United States and Switzerland jointly announced the conversion of the intergovernmental agreement (“IGA”) from a “Model 2” to “Model 1” agreement. The new IGA will come into effect January 1, 2027, allowing time for...more
Memorandum to our Investment Management Clients and Friends -
The United States Tax Court recently issued a ruling (the “Ruling”) pertaining to the possible exclusion of a limited partner’s distributive share of income...more
12/5/2023
/ Audits ,
Cross Motions ,
Fund Managers ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Management ,
IRS ,
Limited Partnerships ,
Motion for Summary Judgment ,
Self-Employment Tax ,
Tax Court
The Corporate Transparency Act (the “CTA”), a set of new regulations being implemented by the Financial Crimes Enforcement Network (“FinCEN”), requires entities newly formed or registered to do business in the United States...more
12/4/2023
/ Beneficial Owner ,
Beneficiaries ,
Corporate Transparency Act ,
Criminal Penalties ,
Deadlines ,
Exemptions ,
FinCEN ,
Grantor Trusts ,
Investment Adviser ,
Investment Companies ,
Investment Funds ,
Limited Liability Company (LLC) ,
Limited Partnerships ,
NDAA ,
Reporting Requirements ,
Trusts