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
In the midst of a downturn in the US economy during the COVID-19 pandemic, structuring transactions in a tax efficient manner will become an even more critical component of achieving optimal investment returns. For example,...more
Key Points -
- As economic pressure intensifies on borrowers, we anticipate debt restructuring and workout transactions will become increasingly necessary. Similarly, dislocations in the debt markets may present...more
On March 27, the United States Congress passed the Coronavirus Aid, Relief, and Economic Security Act or CARES Act, and the President signed the bill into law. The CARES Act provides for $2 trillion in economic stimulus and...more
Beginning in 2018, partnerships (meaning an entity treated as a partnership for tax purposes) generally are subject to the new partnership audit rules. Partnerships may elect out of the new partnership audit rules if they (1)...more
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
Katten previously alerted our readers to the changes in partnership audit rules [See Katten Advisory, "New Partnership Audit Regime Set to Take Effect in 2018, Proactive Planning Recommended," August 7, 2017]. The Internal...more
The "official" House tax reform bill was released by the House Ways and Means Committee on November 9. For the most part, the provisions summarized in Katten's advisory, "Tax Reform: Hedge Funds/Commodity Funds/Fund...more
11/16/2017
/ Alternative Minimum Tax ,
Carried Interest ,
Commodities ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Deferred Compensation ,
Fund Managers ,
Hedge Funds ,
Pending Legislation ,
Self-Employment Tax ,
Tax Deductions ,
Tax Rates ,
Tax Reform
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 November 2, 2015, Congress passed the new centralized partnership audit regime as part of the Bipartisan Budget Act of 2015 (BBA) which is set to take effect for the tax years beginning on or after January 1, 2018. The...more
In a traditional private equity fund, the fund managers will raise money from investors to establish a pool of capital the fund can then use to invest in a number of portfolio companies. A big benefit of a fund is that the...more