In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more
1/31/2025
/ Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Private Equity Funds ,
Private Funds ,
Regulatory Requirements ,
Tax Court ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Reform ,
U.S. Treasury
On April 24, the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding Section 897. In December 2022, the IRS issued proposed regulations under Sections 897 (the Proposed Regulations) and 892...more
The Internal Revenue Service (IRS) recently ruled that if a taxpayer using a cash method of accounting stakes certain cryptocurrency and receives additional units of such cryptocurrency as rewards for staking, the taxpayer...more
The IRS has effectively delayed the implementation of the new digital asset broker rules under Internal Revenue Code Sections 6045 and 6045A.
The US Treasury Department (Treasury) and Internal Revenue Service (IRS) recently...more
The Internal Revenue Service (IRS) and the US Department of the Treasury (Treasury) issued the much-anticipated second set of proposed regulations (the Proposed Regulations) on April 17 regarding Qualified Opportunity Zone...more
In a big win for the industry, final regulations issued by the Internal Revenue Service and US Department of Treasury do not adopt all the rules set forth in the proposed regulations. Instead, regulated investment companies...more
The US Department of the Treasury and the Internal Revenue Service (IRS) released much-anticipated guidance on October 19 on investments in the new Opportunity Zone Funds. The release included proposed regulations...more
The US Department of the Treasury and the Internal Revenue Service on April 2 issued “Initial Guidance Under Section 163(j) as Applicable to Taxable Years Beginning After December 31, 2017” (Notice 2018-28), which announces...more
The recently proposed regulations, if finalized, would govern the treatment of RICs’ income inclusions in respect of CFCs and PFICs for purposes of the income test applicable to RICs; in related guidance, the IRS also...more
The regulations affect both real estate investment trusts (REITs) and regulated investment companies (RICs) that receive appreciated property from a C corporation in a so-called “conversion transaction.”...more
The Treasury and the IRS have delayed implementation of the recently announced rule change that treats certain types of upfront payments on swaps as loans for federal income tax purposes (including for purposes of the...more
10/15/2015
/ Comment Period ,
Debt Financing ,
Dodd-Frank ,
Exceptions ,
Income Taxes ,
IRS ,
Loans ,
Proposed Regulation ,
SIFMA ,
Swaps ,
Tax Exempt Entities ,
U.S. Treasury
Certain individuals having only signature authority over foreign financial accounts now have until June 30, 2015 to file the Report of Foreign Bank and Financial Accounts....more