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Private Equity › Investment Management › Tax Liability

Morrison & Foerster LLP

Tax Court’s Decision in Soroban—Potential SECA Tax Implications for Management Fee Income

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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

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

Akin Gump Strauss Hauer & Feld LLP

From Crackdown to Calibration: The UK’s Evolving Carried Interest Regime

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In November, we covered the UK government’s proposal to overhaul the tax treatment of carried interest in the United Kingdom—an effort to close perceived loopholes by shifting carried interest fully into the income tax...more

Cadwalader, Wickersham & Taft LLP

Another Appeal Adds Fuel to the Limited Partner SECA Tax Debate

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Denham Capital Management LP (“Denham”), a private equity firm, has appealed the recent U.S. Tax Court decision that declined to revisit its interpretation of the “limited partner exception” under the Self-Employment...more

Bennett Jones LLP

High-Net-Worth Investors to Boost Growth in Private Equity: Opportunities, Risks and Other Important Considerations

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Globally, private equity is expected to double its current assets under management (AUM) to US$12 trillion by the end of 2029, driven in large part by private wealth investors, according to new Preqin research....more

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