News & Analysis as of

Limited Partnerships Management Fees

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

Goodwin

Extending Fund Lifespans: Typical Durations and Consent Requirements

Goodwin on

As noted in our previous article, the lifespan of a closed-end fund typically ranges from 8 to 12 years, depending on the asset class. However, to provide flexibility to deal with issues related to illiquidity of assets,...more

Smith Anderson

What Limited Partners Should Know About Soroban

Smith Anderson on

The Tax Court’s use of a functional analysis test to determine limited partner status in Soroban Capital Partners LP has had a ripple effect in the world of asset management. The decision’s impact will be felt in the tax and...more

Akin Gump Strauss Hauer & Feld LLP

[Podcast] Fund Negotiations—Bridging the GP/LP Gap

In this episode, demonstrating solutions in fund formation and negotiation, Akin Gump investment management lawyers Jim Deeken and Gechi Tesic perform a mock negotiation between a private equity firm and a pension fund...more

Katten Muchin Rosenman LLP

ILPA Principles 3.0: Focusing on Enhancing Transparency in Private Equity Funds and Alternative Investments

The Institutional Limited Partners Association (ILPA) recently published the third edition of the ILPA Principles (Principles 3.0). ILPA originally published the principles in 2009 to encourage discussion between general...more

BCLP

Unprecedented expectations around transparency: ILPA Principles 3.0 reflect an evolving and diverse private equity funds industry

BCLP on

The third edition of the ILPA Principles was published in June 2019, replacing and updating the January 2011 second edition. Although the overall goal remains the same, one of improving the private equity industry for the...more

Bennett Jones LLP

New GST/HST Rules Enacted for Fund Management Fee Arrangements

Bennett Jones LLP on

On December 13, 2018, legislation was passed implementing amendments to the Excise Tax Act (Canada) (the “ETA”) first announced in September 2017 affecting GST/HST on management and administrative services provided to private...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

Proskauer Rose LLP

UK 2015 Summer Finance Bill Update: Proposed Taxation Changes for Carried Interest and DIMF

Proskauer Rose LLP on

Further to our client alert in July this year, the UK Government recently proposed further changes to the UK taxation of carried interest and disguised investment management fees (DIMF). The UK Government proposed...more

Katten Muchin Rosenman LLP

IRS Considers Whether Management Fees of an LLC Are Subject to Self-Employment Tax

A recent response by the Internal Revenue Service Chief Counsel (CCA) to an inquiry from one of its field office agents addressed the question of whether management fees earned by an investment manager organized as a limited...more

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