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DLA Piper

Senate Tax Bill: Key Points for the Investment Funds Industry

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The US Senate released a draft tax bill (Senate Tax Bill) on June 16, 2025. We explore five key takeaways for fund sponsors, investors, and the broader asset management community, with a focus on how the Senate Tax Bill...more

Proskauer - Tax Talks

Proposed Changes to Interest Rate Tax Treatment for RICs

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The One Big Beautiful Bill Act (the “OBBBA“), passed by the U.S. House of Representatives (the “House“) on May 22, 2025, is a comprehensive legislative package that seeks to implement sweeping reforms in tax policy,...more

Eversheds Sutherland (US) LLP

The One Big Beautiful Bill’s impact on investments in BDCs

On May 14, 2025, the House Ways and Means Committee approved the so-called “One Big Beautiful Bill” (Bill). We have issued several other alerts regarding the Bill. Among other tax provisions, the Bill includes two provisions...more

DLA Piper

House Committee on Ways and Means Proposed Tax Bill: Key Takeaways

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On May 9, 2025, House Committee on Ways and Means Chairman Jason Smith (R-MO) released a proposed 28-page tax bill, which is scheduled for markup by the House Committee on Ways and Means on May 13, 2025. Below, we highlight...more

K&L Gates LLP

Doing Business in Australia

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Australia welcomes new business and foreign investment by providing a strong economy, a stable political environment and a skilled and talented workforce. Our comprehensive guide to Doing Business in Australia has been...more

Cadwalader, Wickersham & Taft LLP

UK Spring Budget 2024

Key Tax Measures The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Spring Budget for 2024 on 8 March, 2024.  The Budget was delivered against the backdrop of an anticipated general election in the summer...more

Walkers

Guernsey - Protected Cell Companies

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Guernsey was the first jurisdiction to implement the protected cell company ("PCC"), doing so over 25 years ago. The PCC was originally created for use in insurance structures, although today it is also widely used for...more

Walkers

Why MENA-based startups are choosing to incorporate in the Cayman Islands and the British Virgin Islands

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According to a report by data platform Magnitt, the total funding secured by startups in the Middle East and North Africa (MENA) amounted to approximately US$864 million in the first quarter of 2022. Startups in the UAE...more

McDermott Will & Schulte

The 90 Percent Test

McDermott Will & Schulte on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

McDermott Will & Schulte

The Benefits of Investing in a QOF

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Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...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

Goodwin

OCC Grants National Trust Bank Charter to Third Cryptocurrency Firm

Goodwin on

In This Issue. The Office of the Comptroller of the Currency (OCC) granted preliminary conditional approval to a third cryptocurrency firm chartering a national trust bank; the Consumer Financial Protection Bureau (CFPB)...more

Goodwin

Luxembourg 2021 Budget: An Overview Of the Main Tax Amendments which Impact The Fund Industry

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The much-awaited Luxembourg state budget for FY 2021 has finally been tabled before the Chamber of Deputies. Delayed due to the ongoing COVID-19 pandemic, the Luxembourg government published bill number 7666 on 14 October...more

Bowditch & Dewey

IRS Provides More Flexibility for Qualified Opportunity Funds in the Wake of COVID Crisis

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In the wake of the COVID Crisis, on June 4, 2020, the IRS issued Notice 2020-39. The Notice provides much-needed relief for taxpayers investing or considering investing in Qualified Opportunity Funds (“QOFs”). Under...more

Jackson Walker

COVID-19 Relief for Qualified Opportunity Funds

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In Notice 2020-39, the IRS provided relief from several deadlines relevant for investors in qualified opportunity funds (QOFs). This relief generally permits investors and funds to come into compliance by the end of 2020. ...more

Lowndes

Important Year End Deadline for Opportunity Zones

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Opportunity zones provide a powerful tool for taxpayers to defer recognizing their capital gains if they roll over their investment into a qualified opportunity zone fund, and offer investors the potential of avoiding...more

Partridge Snow & Hahn LLP

Final Opportunity Zone Treasury Regulations Released

On Thursday, December 19th, the U.S. Department of Treasury released the long-awaited final Opportunity Zone Treasury Regulations (the “Final Regulations”). The Final Regulations and explanatory materials that span 544 pages,...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

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update: New Proposed Treasury Regulations (Part II)

Qualified Opportunity Zone Businesses - BACKGROUND - In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income...more

McDermott Will & Schulte

Treasury Provides Additional Guidance on Opportunity Zone Provisions

The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more

Foster Garvey PC

Opportunity Zone Funds – Part I: Overview of the Law

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BACKGROUND - Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more

Brooks Pierce

Investing In Qualified Opportunity Funds

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The Tax Cuts and Jobs Act signed on Dec. 22, 2017, amended the tax code to encourage economic growth and investment in designated distressed communities, called qualified opportunity zones, by providing federal income tax...more

Holland & Knight LLP

Opportunity Zone Investments: What You Need to Know and Potential Scenarios - A New Opportunity for Investors to Defer Taxable...

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• The Internal Revenue Service (IRS) on Oct. 19, 2018, issued much anticipated proposed regulations (the Proposed Regulations) and other guidance on tax benefits arising from investments in "qualified opportunity zones" that...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding Tax and Reporting Action Items for Investment Funds and Asset Managers (Fall 2018)

• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...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

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