The UK tax regime for carried interest is being substantially revised from April 2026. This Alert focuses on one particular aspect: the changes to how credit funds should calculate the average holding period (AHP) of their...more
Historically, the ability for investment fund managers to take profits in the form of carried interest has allowed those managers to pay the lower long-term capital gains tax rate (compared to income) so long as the...more
The U.S. Department of Treasury published Final Regulations for the Qualified Opportunity Zone (QOZ) program on January 13, 2020, which answer many, but not all, of the questions arising from the Proposed Regulations released...more
Treasury issued the long-awaited second round of Proposed Regulations yesterday (April 17, 2019), clarifying some key issues in connection with investing in and forming Qualified Opportunity Funds (“QOF”) and the OZ Fund’s...more
After many years of being the target of Congress and the IRS, the Tax Cut and Jobs Act finally succeeded in limiting the beneficial tax treatment of carried interests, at least for some taxpayers. This change will be of...more