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 ,
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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 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