Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more
3/9/2021
/ Corporate Taxes ,
Financial Services Industry ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Investment Management ,
IRS ,
Private Investment Funds ,
Sovereign Wealth Funds ,
Tax Assessment ,
Tax Evasion ,
Tax Liability
The Internal Revenue Service (IRS) and the US Treasury Department released proposed regulations (REG-107213-18) under Section 1061 on July 31 providing guidance to the holders of certain carried interests. These rules are of...more
8/7/2020
/ Capital Gains ,
Carried Interest Tax Rates ,
Financial Services Industry ,
IRS ,
Partnership Interests ,
PFIC ,
Private Investment Funds ,
S-Corporation ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
Final regulations applicable to controlled foreign corporations and their US shareholders, issued by the US Treasury under Code Section 956, generally follow previously proposed regulations but introduce two modifications: a...more
The Internal Revenue Service announced that it has revised the Employer Identification Number application process in order to provide greater security and improve transparency. The revision will require that each applicant’s...more