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
The Internal Revenue Service and the US Department of the Treasury pre-released final regulations, T.D. 9945, under Section 1061 on January 7, providing guidance to the holders of certain carried interests. These rules are of...more
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
The proposed modifications would create opportunities for enhanced CFC credit support.
On October 31, 2018, the US Treasury Department and the Internal Revenue Service (IRS) released proposed Treasury Regulations (the...more
The Internal Revenue Service announces forthcoming regulations in relation to “ECI withholding” under Section 1446(f). It also announces interim relief and guidance for taxpayers pending regulations....more
The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more
7/28/2015
/ Enterprise Risks ,
Fee Waivers ,
Internal Revenue Code (IRC) ,
Intra-Group Transactions ,
Investment Management ,
IRS ,
Management Fees ,
Proposed Regulation ,
Safe Harbors ,
Taxable Distributions ,
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
IRS notice postpones FATCA withholding by six months and revises other key deadlines.
...more