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Private Equity Funds Partnerships Income Taxes

WilmerHale

Court Decision on Limited Partner Exception to Self-Employment Tax

WilmerHale on

On May 28th, the U.S. Tax Court issued a decision in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) holding that all of the income allocable to the partnership’s limited partners (not just the amount...more

A&O Shearman

Final GILTI Regulations and Proposed Regulations on Subpart F Income and GILTI Bring Relief to Private Equity and Other...

A&O Shearman on

On June 14, 2019, the IRS and Treasury finalized the global intangible low-taxed income (GILTI) regulations (T.D. 9866) and issued proposed regulations (REG-101828-19) that will provide significant relief to investors in...more

Bracewell LLP

Bracewell Tax Report: April 2018 part 2

Bracewell LLP on

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Akin Gump Strauss Hauer & Feld LLP

Considerations for Asian Fund Managers under the U.S. New Partnership Audit Regime

The Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, resulted in a fundamental change in the way the U.S. Internal Revenue Service (IRS) will conduct audits of collective...more

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