The “One Big Beautiful Bill Act” (OBBBA), signed into law on July 4, 2025, brings important changes for investment funds. The OBBBA also omits several anticipated provisions that would have adversely impacted investment...more
8/5/2025
/ Carried Interest ,
Investment Funds ,
New Legislation ,
One Big Beautiful Bill Act ,
Pass-Through Entities ,
Private Equity ,
Qualified Small Business Stock ,
SALT ,
Tax Legislation ,
Tax Planning ,
Venture Capital
On July 4, the “One Big Beautiful Bill Act” (OBBBA) was signed into law, which includes provisions restoring immediate deduction of domestic research and experimentation (R&E) expenditures in tax years beginning after...more
On July 4, 2025, the One Big Beautiful Bill Act (OBBBA) was signed into law. It is a landmark piece of legislation that introduces several important changes to the US international tax regime. This alert provides an overview...more
The One Big Beautiful Bill Act (OBBBA), signed into law by President Donald Trump on July 4, 2025, introduces a revised approach to the limitation on deductibility of state and local taxes (SALT cap)....more
On May 22, the US House of Representatives passed the “One Big Beautiful Bill Act” (OBBBA). Among other things, the House bill proposed to add Section 899 to the Internal Revenue Code, which would have increased US tax rates...more
On June 16, the Senate Finance Committee (SFC) released revisions to the “One Big Beautiful Bill Act” (OBBBA) passed by the US House of Representatives on May 22. As described in this June 4 Cooley client alert, the OBBBA...more
On June 16, 2025, the Senate Finance Committee (SFC) released a revised version of the “One Big Beautiful Bill Act” (SFC bill), following the House’s passage of the bill on May 22. The SFC bill would significantly expand the...more
On May 28, 2025, the US Tax Court ruled that investment manager limited partners in Soroban Capital Partners were active limited partners and, as such, were ineligible for the limited partner exception to self-employment...more
On May 22, 2025, the US House of Representatives passed the “One Big Beautiful Bill Act” (OBBBA), which includes a temporary suspension of the amortization requirement for domestic research and experimentation (R&E)...more
In a January 27 client alert, we discussed final regulations issued on December 30, 2024, covering tax reporting requirements applicable to certain decentralized finance (DeFi) platforms operating as noncustodial brokers of...more
On January 10, 2025, the US Department of the Treasury and IRS released final and proposed regulations that provide tax guidance for the digital economy....more
On December 30, 2024, the US Department of the Treasury and IRS issued final regulations providing guidance on tax reporting requirements applicable to certain decentralized finance (DeFi) platforms operating as “brokers” of...more
The US Department of the Treasury (Treasury Department) and the IRS recently released Revenue Procedure 2024-24 (Revenue Procedure) and Notice 2024-38 (Notice) establishing revised standards and procedures for taxpayers...more
On April 12, 2024, the US Department of the Treasury and the IRS published proposed regulations (89 FR 25980 and 89 FR 25829, the “Proposed Regulations”) on the application of Section 4501, which imposes a 1% excise tax on...more
In Announcement 2024-4, the IRS and the US Department of the Treasury stated that, until regulations are issued, taxpayers will not be required to treat digital assets received in the course of their trade or business as cash...more
The IRS recently released Notice 2024-12, which provides some clarifications and modifications to prior IRS guidance relating to the tax treatment of specified research and experimentation (SRE) expenditures pursuant to...more
On November 28, 2023, in Soroban Capital Partners LP v. Commissioner, the US Tax Court denied the taxpayer’s motion for summary judgment, holding that whether a limited partner in a state law limited partnership qualifies for...more
On August 25, 2023, the US Department of the Treasury issued proposed regulations that would impose new information reporting requirements for brokers that facilitate certain transactions involving “digital assets” – if...more
The Tax Cuts and Jobs Act of 2017 (TCJA) introduced significant changes to the tax treatment of specified research and experimentation (SRE) expenditures. Historically, companies were able to immediately deduct all costs...more
On July 31, 2023, the Internal Revenue Service (IRS) released Revenue Ruling 2023-14, which addresses the US federal income tax treatment of cryptocurrency units (commonly referred to as coins or tokens) that are received by...more
The Inflation Reduction Act of 2022 added Internal Revenue Code Section 4501, which imposes a 1% excise tax on certain repurchases of stock of publicly traded US corporations effected after December 31, 2022. As described in...more
The Tax Cuts and Jobs Act was enacted more than five years ago, but certain changes under the legislation are only now coming into focus as taxpayers prepare their 2022 tax returns. In particular, there are significant...more
Startups and emerging companies that are reevaluating their cash management policies following recent events in the banking sector should be aware of the implications of such policies on qualified small business stock (QSBS)...more
The Inflation Reduction Act imposes a 1% excise tax on certain repurchases of stock of publicly traded US corporations (“Covered Corporations”) effected after December 31, 2022 (the “Excise Tax”). On December 27, 2022, the...more
On August 16, 2022, House Resolution 5376, the Inflation Reduction Act (IRA), was signed into law. An August 11 Cooley client alert explains some of the tax provisions contained in the IRA, including the 1% excise tax on...more