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Investors › Proposed Regulation › Income Taxes

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

California FTB Releases Updated Proposed Regulations on Market-Based Sourcing Rules – Implications for Asset Managers

Proskauer - Tax Talks on

On September 13, 2024, California’s Franchise Tax Board (“FTB”) released updated proposed regulations (“Draft Regulations”), which would amend the rules regarding market-based sourcing for sales other than sales of tangible...more

Fenwick & West LLP

PFIC: What U.S. Investment Funds Should be Particularly Aware of and Newly Proposed Regulations

Fenwick & West LLP on

U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules, which could substantially increase the tax owed on exit for U.S....more

McDermott Will & Schulte

Weekly IRS Roundup December 16 – 20, 2019

McDermott Will & Schulte on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

Ballard Spahr LLP

QOZ Update: IRS Provides Relief for Early Investments of Net Section 1231 Gain

Ballard Spahr LLP on

There are many complex and confusing aspects to the qualified opportunity zone (QOZ) program, and the treatment of Section 1231 gain is no exception.  Internal Revenue Code Section 1231 applies to depreciable property and...more

Sheppard Mullin Richter & Hampton LLP

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

Sheppard Mullin Richter & Hampton LLP on

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

McDermott Will & Schulte on

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

Katten Muchin Rosenman LLP

Additional Proposed Regulations Issued Regarding Opportunity Zones

Katten Muchin Rosenman LLP on

As part of the US federal tax reform in 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended (the "Code"), to provide incentives economic growth and investment in designated...more

Foster Garvey PC

Opportunity Zone Funds – Part IV: The Second Round of Proposed Regulations

Foster Garvey PC on

On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more

Holland & Knight LLP

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

Holland & Knight LLP on

• 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

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