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Investment Management › U.S. Treasury › Internal Revenue Service

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

Cadwalader, Wickersham & Taft LLP

Treasury Delivers Mother Lode of Tax Reporting Rules to the Crypto Industry’s Doorstep

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On August 29, 2023, the IRS published detailed proposed regulations addressing digital asset broker reporting requirements (the “Proposed Regulations”). The Proposed Regulations elaborate on the 2021 changes to the Internal...more

Neal, Gerber & Eisenberg LLP

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

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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

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

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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

Troutman Pepper

The Time to Transfer Entity Interests Is Now - Trust and Estates Update Vol. 2015, Issue 1

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Upcoming IRS regulations may significantly limit and reduce planning opportunities to transfer minority interests in closely held entities to family members and increase the transfer tax cost associated with moving such...more

Morgan Lewis

IRS Issues Proposed Regulations Addressing “Fee Waiver” Arrangements

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The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more

McGuireWoods LLP

IRS Determination Letter Program for Qualified Retirement Plans to Be Significantly Curtailed

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In Announcement 2015-19 (Announcement), the Internal Revenue Service (IRS) has indicated that it is eliminating the staggered five-year determination letter (DL) remedial amendment cycles for individually designed...more

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