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Private Equity Capital Gains

Opportune LLP

Tax Implications of the One Big Beautiful Bill Act in the U.S. Energy Industry

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On May 22, 2025, the House Budget Committee approved the President Trump-supported tax legislation called the One Big Beautiful Bill Act (the “OBBBA”). As the OBBBA works its way through Congress with the Senate targeting a...more

Cooley LLP

Senate Tax Bill Expands QSBS Benefits

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On June 16, 2025, the Senate Finance Committee (SFC) released a revised version of the “One Big Beautiful Bill Act” (SFC bill), following the House’s passage of the bill on May 22. The SFC bill would significantly expand the...more

Wilson Sonsini Goodrich & Rosati

Senate Finance Committee Proposes Significant Expansion of the Qualified Small Business Stock (QSBS) Tax Exemption

On June 16, 2025, the Senate Finance Committee released draft text of the tax provisions in the Senate’s version of H.R. 1 (commonly referred to as the “One Big Beautiful Bill” (the SFC Bill)). Notably, the SFC Bill would...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

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On May 22, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). The BBB proposes amendments to the Internal Revenue Code (the Code) that could have...more

Hinckley Allen

Qualified Small Business Stock: Pre-Acquisition Planning for Tax Savings Upon Exit

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Issuing qualified small business stock (“QSBS”) is a valuable tool that can provide significant tax savings to searchers and independent sponsors alike upon the eventual sale of one or more of their portfolio companies....more

Hogan Lovells

The French Finance Act for 2025 reforms the tax and social security regime of management packages and amends the regime applicable...

Hogan Lovells on

The French Finance Act for 2025 radically overhauled the tax and social security treatment of management packages. The BSPCE regime is also subject to some amendments. Key changes and features you need to be aware of: a...more

Cadwalader, Wickersham & Taft LLP

Tax Proposals Bid Adieu to Carried Interest

On February 6, 2025, the Trump Administration announced various tax and budgetary priorities discussed further here, including closing the “carried interest loophole.”  On the same day, Democrats in the House and Senate...more

Fox Rothschild LLP

Trump May Revive Effort to Close Carried Interest Loophole

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President Trump is meeting with Republican lawmakers to discuss potential tax code changes, including a proposal to eliminate the carried interest tax break. White House Press Secretary Karoline Leavitt announced the...more

Seward & Kissel LLP

Carried Interest in the Crosshairs…Again

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On February 6, 2025, Democratic Senators and Representatives proposed the Carried Interest Fairness Act, which would treat carried interest as ordinary income. Additionally, on the same day President Trump met with...more

Dorsey & Whitney LLP

President Trump Seeks to End Carried Interest Tax Preference

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President Trump met with Republican lawmakers on Thursday, February 6, 2025, to outline his tax priorities, including extending the 2017 tax cuts and expanding the state and local tax deduction. Also included among the...more

Foley & Lardner LLP

Physician Practice Private Equity Transactions – A Refresher

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All indications appear to point toward a robust market for health care mergers and acquisitions (M&A) in the coming year. Inflation — finally — appears to be easing. With that, we may continue to see interest rate cuts from...more

Mayer Brown

La prise en compte des reprises et dotations des provisions pour dépréciation de titres de participation pour le calcul de la...

Mayer Brown on

Dans une décision mentionnée aux tables du Recueil Lebon, le Conseil d'Etat affirme la légalité de la doctrine administrative du 3 avril 2024, selon laquelle doivent être prises en compte, pour le calcul de la plus-value...more

Davis Wright Tremaine LLP

Food Venture Financing News - Weekly Issue No. 217

Food Venture Financing Trends - Nexus W2V, a sustainable waste-to-value startup, announced that it raised $140 million in investments....more

Foley & Lardner LLP

Thinking About Selling your Business? Now is the Time

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The economic environment has mostly stabilized following the inflationary shocks of 2021-2022, and a strong Q4 2023 suggests that M&A may be in line for a comeback in 2024. The following trends demonstrate why now is likely a...more

Mintz - Employment Viewpoints

Show Me The Money! Trends in Executive Compensation

As the calendar inches closer to 2024, a pivotal concern looms large in the minds of most employees: cash bonuses. However, for executives, especially those who work for private companies that may be involved in a...more

Troutman Pepper Locke

Rolling Over and Section 704(c); What's the Big Deal? — Part 2: The Traditional Method

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In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner. As...more

Rivkin Radler LLP

Selling Your Business? Careful of Pre-Sale Contributions of Stock to Charity

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Charitable Giving Update- According to a recent report on charitable giving, the number of donors at every level of giving dropped during the first three quarters of 2022. The number of new donors was down by over 19...more

Jackson Lewis P.C.

Carried Interest/Promote in 2022: Action Items for Investment, Private Equity, Real Estate Fund Managers

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Investment, private equity, and real estate fund managers should consider becoming familiar with the complex final regulations on the preferential tax treatment of “carried interest” under Section 1061 of the Internal Revenue...more

Rivkin Radler LLP

The Tax-Deferred Rollover – Some Considerations

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“I have wondered at times what the Ten Commandments would have looked like if Moses had run them through the U.S. Congress.” – Pres. Ronald Regan- That line probably describes the exasperation with which many Americans...more

Rivkin Radler LLP

Selling to Private Equity? Maybe You Should “F Reorg” First

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Having Fun? Hope you had a decent weekend. Perhaps you did something interesting, maybe even fun, like some end-of-season apple picking? Or maybe you had a cider donut with some hot coffee at a farm stand you stumbled upon...more

Rivkin Radler LLP

Gifts, Sales and Effective Dates: The Race Against the Clock the Taxpayer Cannot See

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It was quite a week, wasn’t it?- Manchin- Senator Manchin continued to attract a lot of attention. To the dismay of his fellow Democrats, the West Virginian – who also chairs the Senate Energy and Natural Resources...more

Vinson & Elkins LLP

6 Ideas For Innovating Private Equity Fund Terms

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Aligning the interests of General Partners (GPs) and Limited Partners (LPs) is an essential component of successful private equity funds. Efficient fund terms help GPs and LPs focus on achieving common goals and maximizing...more

Bilzin Sumberg

Tax Planning Considerations for Foreign Clients Making U.S. Private Equity Investments

Bilzin Sumberg on

The United States is no stranger to capital from foreign investors. Perhaps in South Florida especially, this is no more evident than in the real estate market, particularly when it comes to investors from Latin America. Over...more

Ballard Spahr LLP

Carried Interest – Proposed Regulations and the Impact on Private Equity

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Treasury and the IRS released proposed regulations under Section 1061 of the Internal Revenue Code (the Code) on July 31, 2020, that require certain taxpayers to satisfy a three-year holding period, rather than a one-year...more

Proskauer Rose LLP

Key Takeaways from the Proposed Regulations on Carried Interest

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On July 31, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) providing guidance on Section 1061 of the Code, as...more

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