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Private Equity Capital Gains Tax

Latham & Watkins LLP

French Tax Authorities’ Guidelines Clarify the New Legal Framework Applicable to Management Package Instruments

Latham & Watkins LLP on

The regime sets new rules regarding the taxation of gains realized on the sale of securities held by employees or executives in the frame of management packages....more

Seward & Kissel LLP

New Rules for Qualified Small Business Stock in 2025

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The One Big Beautiful Bill Act (the “OBBBA”), which was signed into law on July 4, 2025, contained a big, beautiful surprise for qualified small business stock (“QSBS”) investors. Individual investors, private equity funds...more

Katten Muchin Rosenman LLP

One Big Beautiful Bill Significantly Expands QSBS Benefits and Availability

On July 4, 2025, the One Big Beautiful Bill Act (the "OBBBA") was signed into law. The OBBBA made a number of significant changes to the Internal Revenue Code of 1986, as amended (the "Code"). We write to highlight a handful...more

Katten Muchin Rosenman LLP

HMRC Publishes Draft Legislation for New UK Carried Interest Tax Regime

On July 21, 2025, HM Revenue and Customs (HMRC) published the long-awaited draft legislation (Draft Legislation) for the new UK carried interest tax regime (New Regime) that will apply from April 6, 2026. Under the New...more

Foley & Lardner LLP

Thinking About Selling your Business? Now is the Time

Foley & Lardner LLP on

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

Proskauer Rose LLP

UK Tax Round Up - November 2023

Proskauer Rose LLP on

Welcome to November’s edition of the UK Tax Round Up. This month has seen the Chancellor’s Autumn Statement as well as an interesting confirmation from the Court of Appeal on the scope of “arrangements” for capital gains tax...more

Herbert Smith Freehills Kramer

Final Treasury Regulations Issued Addressing the Application of Section 1061 to Carried Interests

On Jan. 8, 2021, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued final regulations (Final Regulations) (T.D. 9945) governing the treatment of “carried interests” (also referred...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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