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
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
The US Internal Revenue Service (IRS) has updated the Internal Revenue Manual (IRM) to specify which forms taxpayers can electronically sign and which types of electronic signatures are permitted, now on a permanent basis....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
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
The Biden-Harris administration on April 28 introduced the American Families Plan (AFP), a $1.8 trillion legislative framework including provisions to “grow the middle class, expand the benefits of economic growth to all...more
5/3/2021
/ Biden Administration ,
Capital Gains Tax ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Income Taxes ,
IRS ,
Like Kind Exchanges ,
Net Investment Income ,
Tax Credits ,
Tax Rates ,
Tax Reform
With the recent passage of the COVID-19 stimulus package, President Joseph R. Biden, his administration, and Congress have turned their attention to long-term economic recovery, deficit reduction, and tax reform. ...more
House bill, if enacted, will alter tax analysis with respect to fund investments.
On November 2, House Republicans released their draft tax reform bill. Of particular interest to government pension plans is a provision...more