On July 4, 2025, President Trump signed the “One Big Beautiful Bill Act” (OBBB), H.R. 1, into law. The OBBB extended and made permanent the general qualified opportunity fund (QOF) legislative framework for investments in...more
7/21/2025
/ Capital Gains ,
Economic Development ,
Federal Budget ,
Federal Funding ,
Investment ,
New Legislation ,
One Big Beautiful Bill Act ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Rural Areas ,
Rural Development ,
Tax Cuts and Jobs Act ,
Tax Incentives ,
Tax Legislation ,
Tax Reform ,
Trump Administration
On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert released following the passage by the House of...more
7/18/2025
/ Bonus Depreciation ,
Business Losses ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
New Legislation ,
One Big Beautiful Bill Act ,
Opportunity Zones ,
Qualified Business Income ,
Real Estate Investments ,
REIT ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Planning ,
Tax Reform ,
Trump Administration
FUNDamentals is a periodic digest of news and information specifically for private funds and their managers. In this issue, we highlight some fundraising trends, new marketing rule FAQs, fund liquidity trends (limited...more
6/17/2025
/ Federal Budget ,
Financial Markets ,
Financial Services Industry ,
Fund Managers ,
Investment ,
Investment Funds ,
Investment Management ,
Limited Partnerships ,
Liquidity ,
Private Equity ,
Private Equity Funds ,
Proposed Legislation ,
Regulatory Reform ,
Regulatory Requirements ,
Trump Administration
In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more
6/11/2025
/ Banks ,
Borrowers ,
Consumer Financial Products ,
Corporate Taxes ,
Federal Budget ,
Financial Institutions ,
Financial Services Industry ,
Foreign Banks ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Loans ,
Regulatory Requirements ,
Tax Liability ,
Trump Administration ,
Withholding Tax
On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more
6/5/2025
/ Federal Budget ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Proposed Amendments ,
Proposed Legislation ,
Real Estate Development ,
Real Estate Investments ,
REIT ,
Tax Credits ,
Tax Deductions ,
Tax Reform ,
Trump Administration
Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more
6/2/2025
/ Banks ,
Borrowers ,
Consumer Financial Products ,
Consumer Lenders ,
Federal Budget ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Foreign Financial Institutions (FFI) ,
Foreign Investment ,
Income Taxes ,
Interest Payments ,
International Tax Issues ,
Lenders ,
Loans ,
Pending Legislation ,
Proposed Legislation ,
Regulatory Agenda ,
Tax Liability ,
Tax Reform ,
Trump Administration ,
Withholding Tax
When a borrower struggles to meet the payment obligations of a debt instrument, the borrower and creditor may work together to modify some of the terms to give the borrower a little breathing room or provide the creditor with...more
On March 22, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-30, which modifies prior guidance on the energy community enhancements. It further clarifies (a) when offshore...more
The Internal Revenue Code permits a business bad debt deduction when a customer fails to pay for the services rendered or the products supplied by your business. However, the ability to claim an ordinary deduction with...more
3/22/2024
/ Bankruptcy Code ,
Commercial Bankruptcy ,
Creditors ,
Debtor-Creditor ,
Debtors ,
Financial Services Industry ,
Insolvency ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Deductions ,
Tax Liability
In April 2022, opportunity zone (OZ) legislation — H.R. 7467 or the Opportunity Zones Improvement, Transparency and Extension Act — was introduced, but not enacted. Among other items, that legislation included proposals to...more
In April, the Department of the Treasury released the second round of regulations related to the opportunity zone program. Some highlights include...
Originally published in Middle Market Growth, the official publication...more
8/13/2019
/ Capital Assets ,
Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
Investors ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
S-Corporation ,
Safe Harbors ,
Tax Deferral ,
Tax Planning ,
Triggering Event ,
U.S. Treasury
In April, the Department of the Treasury released the much-anticipated second round of Treasury Regulations under section 1400Z-2 of the Internal Revenue Code (April Regulations). This article provides certain highlights of...more
7/1/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives ,
Tax Planning
When a taxpayer is considering purchasing a foreign corporation, tax planning must be part of the process in order to mitigate unwanted tax consequences. For example, an election under section 338(g) of the Code has been a...more
Careful Evaluation and Planning Should Be Undertaken When the Partnership Is Formed and When Assets Are Contributed to Evaluate the Potential Impact of Section 721(b).
Many taxpayers choose partnership structures...more
Issuers and their advisors need to be aware of the potential pitfalls and uncertainties of the applicable high-yield discount obligation rules, which can have the effect of permanently disallowing a portion of interest...more
Where Qualified Dividend Treatment Is Important, Serious Consideration Should Be Given to Ensuring the Company Is Eligible for Treaty Benefits Before Taking It Public.
Dividends generally are taxed at ordinary income...more
7/8/2015
/ Australian Stock Exchange ,
Capital Gains ,
Dividends ,
Initial Public Offering (IPO) ,
IRS ,
Jurisdiction ,
London Stock Exchange ,
Nasdaq ,
Publicly-Traded Companies ,
Qualified Foreign Corporation ,
Securities and Exchange Commission (SEC) ,
Stock Exchange ,
Stocks ,
Tax Rates ,
Tax Treaty ,
Toronto Stock Exchange