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Private Equity Investment Funds Income Taxes

Hogan Lovells

UK carried interest regime: draft legislation confirms scope and conditions

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On 21 July 2025, the UK Government published draft legislation for the new UK carried interest regime, which is expected to come into effect from 6 April 2026. As previously announced, the draft legislation provides for...more

Latham & Watkins LLP

The UK’s New Regime for Carried Interest Taxation - How the Draft Legislation Stacks Up

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On 21 July 2025, the UK government published draft legislation relating to its new carried interest regime. This Client Alert considers key aspects of the new regime and how it may apply to UK-based asset managers and non-UK...more

Mintz - Tax Viewpoints

New Option for Excess Fee Income Rebates in Private Equity Funds for Non-US and US Tax-Exempt Investors

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This update discusses a new and interesting development with respect to how certain non-US and US tax-exempt investors can receive a “rebate” of previously paid management fees with respect to their investments in private...more

Stinson LLP

U.S. Tax Court Issues Ruling on Self-Employment Tax Exception for Limited Partners

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On Wednesday, May 28, the U.S. Tax Court ruled in Soroban Capital Partners LP v. Commissioner that a "functional analysis" test applies when determining whether a limited partner who contributes services to a partnership may...more

Rivkin Radler LLP

The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?

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An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...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

Goodwin

UK Government announces update on new carried interest tax regime

Goodwin on

On June 5, 2025, the UK Government announced the result of their recent consultation process regarding their plans to bring carried interest within the income tax regime from April 2026, subject to an effective tax rate of...more

White & Case LLP

The IRS Continues Winning Self-Employment Contributions Act (SECA) Tax Against Limited Partners in Private Equity and Hedge Funds

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Recently, the Internal Revenue Service ("IRS") has successfully asserted that limited partners in private equity and hedge funds that are organized as limited partnerships were subject to tax under the Self-Employment...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Investment Funds and Sponsors

Troutman Pepper Locke on

On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more

Hogan Lovells

Carried interest schemes for asset managers

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During the last decade, the shape and source of capital flows and investment have fundamentally shifted. Private capital continues to flow into all asset classes including real estate, infrastructure, private credit, and...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

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

Foley & Lardner LLP

Tax Court Reaffirms Soroban Holding that “Active” Limited Partners are Subject to Self-Employment Tax

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On December 23, 2024, the Tax Court ruled in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), that limited partners that actively participated in the activities of a fund manager formed as a state law...more

Proskauer Rose LLP

UK Tax Round Up - January 2020

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UK General Tax Developments - Date set for next UK Budget - The first Budget of the new Conservative government will be held on Wednesday 11 March. There has been significant speculation that there will be a major...more

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