At this point, private equity firms are very conscious that debt of their U.S. acquisition vehicles or portfolio companies cannot be guaranteed by controlled foreign corporations (CFCs), nor can more than 65 percent of the...more
As we previously reported, following the tax reform package passed in December, private equity limited partner investors based outside the United States are now subject to tax on gains from the sale of partnership interests....more
4/27/2018
/ Capital Gains ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Partnership Interests ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
Withholding Tax
Corporate inversions have been the target of regulatory or statutory tax proposals for many years. However, the recently attempted combination of Pfizer and AstraZeneca received prompt and more far-reaching attention in the...more
On February 26, 2014, U.S. Rep. David Camp (R-MI), chairman of the House Ways and Means Committee, released a draft of the Tax Reform Act of 2014 (TRA 2014), which would provide for the most significant tax reform since the...more