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Private Fund Industry Update: the Key Tax Developments That Shaped 2023

2023 saw a number of key tax developments that may affect the private fund industry going into 2024, from key US Tax Court opinions and updates to Internal Revenue Service (IRS) Forms, to new regulations proposed by the IRS...more

US Tax Court Decision Opens Limited Partners to Self-Employment Tax Exposure

Private equity, hedge fund, and other investment fund sponsors should be aware of the recent development in the Internal Revenue Service’s (IRS’s) audit campaign with respect to potential liability for Self-Employment...more

Taxpayer Victory in US Tax Court Highlights Need for Properly Structuring Partnership Profits Interests

A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a...more

US Tax Court Will Weigh In on Self-Employment Tax for Limited Partners

Private equity, hedge fund, and other investment fund sponsors should be aware that there continue to be significant developments in the Internal Revenue Service's (IRS’s) audit campaign with respect to the potential...more

IRS Provides Guidance on Elections Related to Section 163(j) Business Interest Limitation

Revenue Procedure 2020-22 from the Internal Revenue Service provides helpful flexibility for taxpayers in a real property trade or business. ...more

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