While the final regulations simplify key exceptions and contain favorable changes, ambiguity continues for investment fund managers.
On January 7, 2021, the US Treasury Department and Internal Revenue Service (together,...more
While the proposed carried interest regulations clarify key aspects, the proposed rules leave some ambiguity for investment fund managers.
Section 1061 is intended to limit long-term capital gain treatment attributable to...more
Proposed regulations under Section 864(c)(8) provide guidance for determining a foreign partner’s effectively connected gains or losses from a transfer of its interest in a partnership engaged in a US trade or...more
Summary of private equity firms’ compliance obligations, discussion of notable developments in 2015 and outlook for 2016.
US federal laws and regulations, as well as the rules of self-regulatory organizations (SROs),...more
2/9/2016
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Year-End Compliance Checklist
Certain arrangements would be recharacterized as ordinary income, rather than as distributive shares of partnership income.
On July 22, 2015, the US Treasury Department and the US Internal Revenue Service (IRS) released...more