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Morrison & Foerster LLP

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

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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

Akin Gump Strauss Hauer & Feld LLP

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

Akin Gump Strauss Hauer & Feld LLP on

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

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

Proskauer Rose LLP

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

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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

Katten Muchin Rosenman LLP on

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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