Under current (post-2017) federal income tax law, long-term capital gain allocated to or realized by a non-corporate recipient of a promote or other performance-based allocation (a "Carried Interest") in the investment...more
As part of the US federal tax reform in 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended (the "Code"), to provide incentives economic growth and investment in designated...more
4/24/2019
/ Anti-Abuse Rule ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Opportunity Zones ,
Partnerships ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Transactions ,
S-Corporation ,
Safe Harbors ,
Tangible Property ,
U.S. Treasury
On October 31, the Internal Revenue Service (IRS) released proposed regulations (the "Proposed Regulations") under Section 956 that could substantially increase the collateral packages made available by US corporate borrowers...more
11/6/2018
/ Controlled Foreign Corporations ,
Corporate Financing ,
Dividends ,
Domestic Corporations ,
GILTI tax ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Section 956 ,
Shareholders ,
Subsidiaries ,
U.S. Treasury
On October 19, the Internal Revenue Service (IRS) and US Department of the Treasury released the first set of proposed regulations under Internal Revenue Code Subchapter Z—Opportunity Zones (Proposed Regulations). On the same...more
10/23/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Planning ,
U.S. Treasury
The Tax Cuts and Jobs Act proposed by the US House of Representatives on November 2 (House Bill) proposes major modifications to employee and partner compensation and benefits-related provisions of the Internal Revenue Code,...more
11/10/2017
/ Carried Interest ,
Corporate Taxes ,
Deferred Compensation ,
Excise Tax ,
Executive Compensation ,
Income Taxes ,
Individual Retirement Account (IRA) ,
Internal Revenue Code (IRC) ,
Partnerships ,
Pending Legislation ,
Recharacterization ,
Section 409A ,
Tax Exempt Entities ,
Tax Reform ,
Vesting
House Republicans released their draft tax bill on November 2, representing their opening bid in the drive to reach agreement on a comprehensive tax reform bill that can be presented to the House for a vote before the...more
11/9/2017
/ Alternative Minimum Tax ,
Corporate Taxes ,
Deferred Compensation ,
Hedge Funds ,
Income Taxes ,
Investment Funds ,
Investment Management ,
Pass-Through Entities ,
Proposed Legislation ,
Tax Rates ,
Tax Reform
On July 29, Windstream announced that it plans to spin off certain telecommunications network assets into an independent, publicly traded real estate investment trust (REIT). Windstream made the announcement after it obtained...more