News & Analysis as of

Management Fees Limited Partnerships Investment Funds

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

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

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