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Investment Management Tax Liability

ASKramer Law

Tax-Loss Harvesting Part III: Investment Strategies

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Taxpayers invest to make money and hope to earn a decent return on their investments. Tax-loss harvesting can be used as part of a taxpayer’s overall investment strategy without affecting investment  returns, while offsetting...more

Morrison & Foerster LLP

Tax Court’s Decision in Soroban—Potential SECA Tax Implications for Management Fee Income

On May 28, 2025, the U.S. Tax Court issued its decision in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) (“Soroban”), holding that “limited partners” of a management company organized as a Delaware limited...more

Rivkin Radler LLP

The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?

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An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more

Husch Blackwell LLP

U.S. Tax Court Rules That Limited Partners of an Investment Manager Are Subject to Self-Employment Tax

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On May 28, 2025, the United States Tax Court held that the limited partners of a limited partnership providing investment management services to various investment funds were not limited partners within the meaning of...more

Akin Gump Strauss Hauer & Feld LLP

From Crackdown to Calibration: The UK’s Evolving Carried Interest Regime

In November, we covered the UK government’s proposal to overhaul the tax treatment of carried interest in the United Kingdom—an effort to close perceived loopholes by shifting carried interest fully into the income tax...more

Cooley LLP

Soroban: An Update After US Tax Court Ruling

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On May 28, 2025, the US Tax Court ruled that investment manager limited partners in Soroban Capital Partners were active limited partners and, as such, were ineligible for the limited partner exception to self-employment...more

Cadwalader, Wickersham & Taft LLP

Another Appeal Adds Fuel to the Limited Partner SECA Tax Debate

Denham Capital Management LP (“Denham”), a private equity firm, has appealed the recent U.S. Tax Court decision that declined to revisit its interpretation of the “limited partner exception” under the Self-Employment...more

Foley & Lardner LLP

YA Global Heads to Appeals Court Over Tax Court Ruling on Offshore Fund’s U.S. Activities

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Share on LinkedIn Share on Twitter Print Share by Email Share Back to top Last month, YA Global Investments, LP (the “Fund”) filed a notice of appeal to the U.S. Court of Appeals for the Third Circuit, seeking review of the...more

Ropes & Gray LLP

Impact of Permanent Establishment Reform for Credit Funds

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On 28 April, the UK Government produced draft legislation for consultation as the latest step in the reform of UK rules on transfer pricing, permanent establishments and diverted profits tax. From an asset management...more

Bennett Jones LLP

High-Net-Worth Investors to Boost Growth in Private Equity: Opportunities, Risks and Other Important Considerations

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Globally, private equity is expected to double its current assets under management (AUM) to US$12 trillion by the end of 2029, driven in large part by private wealth investors, according to new Preqin research....more

Offit Kurman

Maximizing Financial Growth: Insights on HSAs and Smart Investment Strategies with Shaun Eddy

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In this episode of Real Talk, Real Growth, host Linda Ostovitz welcomes Shaun Eddy, CEO and partner at Oxford Planning Group. Shaun, a certified financial planner with a master's degree in financial analysis, explores the...more

Strafford

[Webinar] Tax Treatment of Leveraged Blockers Used by Foreign Investors: Recent IRS Guidance, Deal Structures, Tax Planning - June...

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This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. assets utilizing leveraged blockers and other tax planning...more

Nelson Mullins Riley & Scarborough LLP

Death, Taxes, and Crypto Reporting – The Three Things You Cannot Escape

The IRS released a draft of Form 1099-DA “Digital Asset Proceeds from Broker Transactions” in April which will require anyone defined as a “broker” to report certain information related to the sale of digital assets. The new...more

Cadwalader, Wickersham & Taft LLP

Location, Location, Location: New York’s Apportionment Rules for Investment Managers

New York State recently issued final corporate franchise tax regulations for sourcing income (the “Regulations”), including specific sourcing rules for service fees paid by passive investment customers (“PICs”) to investment...more

Cadwalader, Wickersham & Taft LLP

Limited Partner Exception Challenged by Hedge Fund Legend

An investment management firm founded and owned by legendary investor (and New York Mets owner) Steve Cohen on August 11 filed a petition in Tax Court contesting an IRS audit adjustment in the amount of $344,063,484 for tax...more

Cadwalader, Wickersham & Taft LLP

UK Government Considering Expansion of Investment Transactions List to Include Crypto-Assets

The UK Government has announced a public consultation regarding the possible expansion of the UK’s investment manager exemption (“IME”) to encompass crypto-assets. The IME enables UK-based fund managers to provide...more

Morgan Lewis

Sovereign Wealth Funds Update: Tax Aspects of Private Fund Investments: Selected US, EU, and UK Considerations in the Current...

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Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more

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

PRIVATE PLACEMENT LIFE INSURANCE WEBINAR

Discussion Points: a. Why financial advisors and life insurance agents should be selling PPLI now. b. An overview of the current lay of the land in PPLI. c. The important tax rules of PPLI. d. Planning examples using...more

McDermott Will & Schulte

[Event] 2019 Private Client East Coast Forum - November 21st, New York, NY

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The unique needs of ultra-high net worth families, their family office representatives and other advisers are multidimensional and ever-evolving. Join us November 21 for McDermott Will & Emery’s Private Client East Coast...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

Foodman CPAs & Advisors

Los titulares de Moneda Virtual (MV) NECESITAN MANTENER REGISTROS

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La Sección 6001 del Código de Rentas Internas requiere que los Contribuyentes mantengan libros y registros adecuados. Mantener libros adecuados y buenos registros de la MV ayudará al Contribuyente a...more

Foodman CPAs & Advisors

Virtual Currency (VC) Holders NEED to KEEP RECORDS

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Internal Revenue Code Section 6001 requires Taxpayers to maintain adequate books and records. Keeping adequate VC books and good records will assist a Taxpayer to...more

Burr & Forman

South Carolina Property Tax for New and Expanding Manufacturers: The Fee-In-Lieu of Tax Versus the Special Source Revenue Credit

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South Carolina has some of the highest business property taxes in the Southeast. The state generally taxes land, buildings, machinery and equipment, and furniture and fixtures, but does not tax inventory, pollution control...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

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