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
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