Exploring Carried Interest in Upper Tier Private Equity Structures — PE Pathways
4 Key Takeaways | Mid-Year Tax Update
THE WAY WE WERE
Investment Management Update – Exit Strategies
Podcast: Introduction to Credit Funds: Basics on How Credit Funds and Private Equity Funds Differ
Episode 26: Talking Tax Reform and Executive Comp
Jeffrey DeBoer on the intersection of Washington and commercial real estate
Waterfalls in private equity and venture capital dictate how investment returns are distributed among stakeholders. These structures determine who gets paid, in what order, and under what conditions. While all waterfalls aim...more
On Wednesday 30 October 2024, the UK government announced changes to the UK taxation of carried interest as part of the 2024 Autumn Budget. Changes were expected following statements made by the Labour Party in the run up to...more
On July 27, 2022, Senate Majority Leader Chuck Schumer and Senator Joe Manchin announced their agreement on proposed legislation (the “Inflation Reduction Act of 2022” or “Act”) that is expected to be considered by the Senate...more
In this episode of Public Pensions & Investments Briefings, Nossaman Public Pensions & Investments Group Partner Peter Mixon and Institutional Limited Partners Association Senior Policy Counsel Chris Hayes discuss what impact...more
Using the Loan Method of Split Dollar to recreate the benefit of tax deferral for Hedge Fund Managers in lieu of carried interest in their offshore fund.#splitdollar #ppli #estateplanning #financialadvisors #finance...more
We are often asked about the prevalent market options for structuring carried interest provisions in venture capital funds. In this post, we’ll speak of mainstream venture capital funds, so to speak. Terms differ in special...more
Hong Kong’s private funds industry is on the verge of benefitting from further significant changes in local laws designed to make Hong Kong more attractive as a centre for private funds and their managers. On 31 August 2020,...more
On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more
On July 31, 2020, the U.S. Internal Revenue Service (the "IRS") and the U.S. Treasury Department ("Treasury") issued proposed regulations (the "Proposed Regulations") that provide taxpayers with definitional and computational...more
We at The Capital Commitment blog have previously discussed several steps for fund managers and others to weather the storm brought by COVID-19. One of those steps is assessing the likelihood of a carried interest return...more
The Institutional Limited Partners Association (ILPA) recently published the third edition of the ILPA Principles (Principles 3.0). ILPA originally published the principles in 2009 to encourage discussion between general...more
New development: The IRS has issued guidance that the exception to the new 3-year hold requirement for carried interests held by “corporations” does not apply to S corporations. As previously discussed, the 2017 Tax Cuts...more
Prior to the passage of the Tax Cuts and Jobs Act (the “Act”), one of the more controversial and hotly-debated tax benefits was the so-called “carried interest,” which allowed certain fund managers and venture capital firms...more
Effective immediately, there is a new requirement that each particular portfolio company interest which is the subject of a disposition event needs to have been held by the fund for more than 3 years in order for the...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
In recent months, managers of private equity funds in the energy sector have been facing a scenario they likely never imagined: having to return millions of dollars of their “carried interest” earnings back to investors....more
The Belgian Stock Option Law sets out the tax treatment of stock options, thereby eliminating the uncertainty as to the taxable value of the stock options. In the past, the Belgian Ruling Commission has been reluctant to...more
On February 9th, President Obama released his Budget Proposals for 2017 (the "Budget Proposals"). The Budget Proposals include the following proposals that may affect private investment fund managers...more
On July 22, 2015, the U.S. Department of the Treasury issued proposed regulations addressing the tax treatment of certain private equity management fee waivers. These new rules could result in many common management fee...more
New rules effective from today in the U.K. are likely to have material impact on the tax treatment of payments by a fund to its U.K.-based management executives and service providers. The rules cover many areas of fund...more