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Carried Interest Estate Tax Investment Funds

Foley & Lardner LLP

One Big Beautiful Bill Act – Tax Considerations for Investment Funds

Foley & Lardner LLP on

On July 4, 2025, President Donald Trump signed into law extensive tax legislation as part of the One Big Beautiful Bill Act (OBBBA) that will impact the investment fund industry.  Perhaps one of the most important aspects...more

Gerald Nowotny - Law Office of Gerald R....

Looking Over the Edge of the Cliff– The Use of Pooled Income Funds for the Repatriation of Offshore Carried Interest

The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more

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