Asset Management, Internal Revenue Code (IRC), Tax Liability

Senate Tax Bill: Key Points for the Investment Funds Industry

DLA Piper on 6/24/2025

The US Senate released a draft tax bill (Senate Tax Bill) on June 16, 2025. We explore five key takeaways for fund sponsors, investors, and the broader asset management community, with a focus on how the Senate Tax Bill...more

Key Updates to the House Committee on Ways and Means’ Proposed Tax Bill

DLA Piper on 5/15/2025

On May 12, 2025, the House Committee on Ways and Means Chairman Jason Smith (R-MO) released an amended 389-page bill, entitled “The One, Big, Beautiful Bill,” and the staff of the Joint Committee on Taxation released a...more

Federal Income Taxation of Intellectual Property Development and Cost Recovery

Gray Reed on 4/10/2024

Intellectual property (“IP”) development can cost millions of dollars so cost recovery timing can be financially material. General tax principles typically require that expenses associated with creating assets having useful...more

Top Tax and Legal Considerations for Wealthy Families Going Global

Greenberg Glusker LLP on 10/5/2023

In recent years, we have seen high net-worth and ultra-high-net-worth families become, increasingly, “global citizens.” As families and their assets touch multiple jurisdictions, a myriad of issues become especially important...more

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on 10/3/2023

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Taxation of Derivatives Held by Investors: What to Know

ASKramer Law on 3/22/2023

The taxation of derivatives and financial products has developed in an uncoordinated and piecemeal fashion. Tax rules have largely been enacted in response to what the government has perceived as abusive transactions —...more