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Internal Revenue Service › Private Funds › Investment Management

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.  
Morrison & Foerster LLP

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

Morrison & Foerster LLP on

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

Foley & Lardner LLP

Section 1446(f) Withholding and Private Fund Admissions and Withdrawals

Foley & Lardner LLP on

Withholding Under Code Sections 1446(a) and 1446(f) A partnership, such as a fund treated as a partnership for U.S. federal income tax purposes, that realizes income effectively connected with the conduct of a trade or...more

Akin Gump Strauss Hauer & Feld LLP

Investment Management Special Report - 2017-18 Compliance Developments & Calendar for Private Fund Advisers

Akin Gump Strauss Hauer & Feld LLP on

Introduction - Despite an anticipated de-regulatory push, there are significant new regulatory concerns for investment advisers to address in connection with their annual review of their compliance manuals. ...more

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