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Internal Revenue Service Private Equity Firms

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
ArentFox Schiff

Let It Be…Taxed? The Carried Interest Debate Continues

ArentFox Schiff on

On February 6, Congressional Republican leaders met with President Donald Trump to address the Trump Administration’s 2025 budget and tax priorities. During that meeting, the Trump Administration proposed to eliminate capital...more

DLA Piper

2025 Carried Interest Tax Reform and Impact on Sponsors and Investors

DLA Piper on

On February 6, 2025, President Donald Trump met with Republican lawmakers to discuss budget priorities, proposing to end carried interest. On the same day, Democrats introduced bills in both the House and the Senate that...more

Troutman Pepper Locke

Rolling Over and Section 704(c); What’s the Big Deal? — Part 4: The Remedial Method

Troutman Pepper Locke on

In our continuing series on Section 704(c) of the Internal Revenue Code (the Code) we discuss the application of the remedial method to correct for distortions caused by the ceiling rule. As previously discussed, when the tax...more

Troutman Pepper Locke

Rolling Over and Section 704(c); What's the Big Deal? — Part 3: The Traditional Method With Curative Allocations

Troutman Pepper Locke on

Continuing with our series on the implications of the application of Section 704(c), the below discussion addresses the use of the traditional method with curative allocations. In Part 1 [insert link] we gave a broad overview...more

Troutman Pepper Locke

Rolling Over and Section 704(c); What's the Big Deal? — Part 2: The Traditional Method

Troutman Pepper Locke on

In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner. As...more

Troutman Pepper Locke

Rolling Over and Section 704(c); What's the Big Deal? — Part 1: The Basics

Troutman Pepper Locke on

When entering into a partnership agreement where one partner is contributing cash and another partner is contributing appreciated property, inevitably, a tax advisor is going to ask, which Section 704(c) allocation method...more

Alston & Bird

How Is Congress Trying to Regulate Private Equity in Health Care?

Alston & Bird on

Our Health Care Group investigates congressional efforts to require new transparency disclosures to the IRS from private equity firms invested in health care....more

Pillsbury Winthrop Shaw Pittman LLP

Inflation Reduction Act of 2022 Includes New Corporate Tax Provisions

The new law generally imposes a 15% alternative minimum tax on book income of corporations with book income in excess of $1 billion. Public companies will generally be subject to a 1% excise tax on stock buybacks. ...more

Fenwick & West LLP

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

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