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Fund Managers Income Taxes

Hogan Lovells

The limited partner exception from self-employment taxes: Soroban II

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The latest chapter in the IRS attack on the use of a self-employment tax exception by fund managers came in the form of another Tax Court opinion last month in Soroban Capital Partners LP v. Commissioner (“Soroban II”) The...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Investment Funds and Sponsors

Troutman Pepper Locke on

On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more

WilmerHale

Court Decision on Limited Partner Exception to Self-Employment Tax

WilmerHale on

On May 28th, the U.S. Tax Court issued a decision in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) holding that all of the income allocable to the partnership’s limited partners (not just the amount...more

Alston & Bird

Asset Managers with California Investors Could Face New State and Local Taxes

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Our State & Local Tax Team breaks down proposals from both California and San Francisco that would use investors’ location to decide whether to tax out-of-state asset managers....more

Proskauer - Tax Talks

Taxing carried interest in the UK: the new regime announced in the Labour government’s Autumn Budget 2024

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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

International Lawyers Network

Establishing a Business Entity in Singapore (Updated)

Registration of Business Entities - Unless exempted, business entities must be registered with the Accounting and Corporate Regulatory Authority (ACRA) via their business filing portal: BizFile+. A foreigner residing...more

International Lawyers Network

Establishing A Business Entity In Singapore (Updated)

Registration of Business Entities - Unless exempted, business entities must be registered with the Accounting and Corporate Regulatory Authority (ACRA) via their business filing portal: BizFile+. A foreigner residing...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Federal Court Authorizes Service of John Doe Summons Seeking Cryptocurrency User Identities

Back in 2005 when I was a trial attorney at the United States Department of Justice, I worked to enforce the John Doe summons on PayPal, Inc. in the federal district court in the Northern District of California, which summons...more

International Lawyers Network

Establishing A Business Entity In Singapore (Updated)

Registration of Business Entities - Unless exempted, business entities must be registered with the Accounting and Corporate Regulatory Authority (ACRA) via their business filing portal: BizFile+. A foreigner residing...more

Goodwin

New Developments on the VAT Exemption for Fund Management Services

Goodwin on

On 17 June 2021, the Court of Justice of the European Union (CJEU) rendered two decisions about the application of the VAT exemption for management services provided in article 135 (1) (g) of the EU VAT Directive and...more

International Lawyers Network

Establishing A Business Entity In Singapore

Registration of Business Entities - Unless exempted, business entities must be registered with the Accounting and Corporate Regulatory Authority (ACRA) via their business filing portal: BizFile+. A foreigner residing...more

Proskauer Rose LLP

UK Tax Round Up - October 2020

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UK COVID-19 Developments - UK Prime Minister’s statement on COVID-19 - On 31 October, the Prime Minister announced a number of measures designed to slow down the spread of COVID-19 to last for four weeks from 4...more

Neal, Gerber & Eisenberg LLP

Fund Managers and Family Offices Get Some Clarity on Carried Interests with Issuance of Proposed Treasury Regulations

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

Cooley LLP

Blog: Primer - U.S. Tax Considerations for Venture Capital Funds

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We are frequently asked by our fund manager clients about what tax issues they should consider when forming a new venture capital fund or investing in portfolio companies. In this post, we outline a few key considerations for...more

Akin Gump Strauss Hauer & Feld LLP

Upper Tribunal Overturns Decision on Tax Treatment of Management Fee Rebates

The Upper Tribunal (UT) has found that amounts paid by Hargreaves Lansdown (HL) (an investment platform service provider) to its customers, which represented rebates received from investment fund managers, were “annual...more

Akin Gump Strauss Hauer & Feld LLP

Opportunity Zones: How Communities Can Leverage This New Provision to Jumpstart Investment

• Even though practitioners are awaiting proposed regulations on the new opportunity zone provision, interested parties are already starting to set up qualified opportunity funds to pool investor capital. • States, cities,...more

Akin Gump Strauss Hauer & Feld LLP

Mixed Funds – Limited Window for Cleansing Until 5 April 2019

• Individuals that are UK tax resident and non-UK domiciled have the ability until 5 April 2019 to cleanse their mixed overseas funds and accounts. • Affected individuals should act now to review their position and assess...more

Burr & Forman

New Carried Interest Rules of Interest to Real Estate Developers and Asset Managers

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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

Akin Gump Strauss Hauer & Feld LLP

Considerations for Asian Fund Managers under the U.S. New Partnership Audit Regime

The Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, resulted in a fundamental change in the way the U.S. Internal Revenue Service (IRS) will conduct audits of collective...more

Herbert Smith Freehills Kramer

Funds Talk: July 2017 - Structuring Considerations for Direct Lending Funds

Kramer Levin’s Alternative Investment Management practice recently hosted “Structuring Considerations for Direct Lending Funds,” a seminar designed to assist those fund managers who form investment vehicles to lend to small...more

Proskauer Rose LLP

Proposed Regulations Issued On Management Fee Waivers

Proskauer Rose LLP on

On July 22, 2015, the U.S. Department of the Treasury and U.S. Internal Revenue Service issued proposed Treasury Regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended, addressing management...more

Troutman Pepper

Fund Managers, Welcome to the Hotel California - When It Comes to Certain Taxes, It's Possible You Can Never Leave - Tax Update...

Troutman Pepper on

Fund Managers May Be Taxable in California, Even if the Manager Has No Property or Payroll in California and All of the Management Services Are Performed Outside of the State. Several recent law changes in California,...more

Skadden, Arps, Slate, Meagher & Flom LLP

A Guide to the UK Disguised Investment Management Fee Rules

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

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

After the Love is Gone – Tax Planning Considerations for Private Equity and Venture Capital Fund Managers in a Post-Carried...

Overview - The issue of carried interest taxation as obscure an issue as it is, has gotten all kinds of attention in the media over the last several years. Most recently, the issue garnered national attention during...more

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