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Akin Gump Strauss Hauer & Feld LLP

From Crackdown to Calibration: The UK’s Evolving Carried Interest Regime

Akin Gump Strauss Hauer & Feld LLP on

In November, we covered the UK government’s proposal to overhaul the tax treatment of carried interest in the United Kingdom—an effort to close perceived loopholes by shifting carried interest fully into the income tax...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Government Targets Reform of the Investment Manager Exemption

Skadden, Arps, Slate, Meagher & Flom LLP on

On 28 April 2025, the UK government published draft legislative amendments to: - Align the UK’s domestic tax rules on permanent establishments (PE) with the 2017 Organisation for Economic Co-operation and Development (OECD)...more

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

DarrowEverett LLP on

The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

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