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Morrison & Foerster LLP

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

Morrison & Foerster LLP on

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

Coblentz Patch Duffy & Bass

Donating Fund Interests: A “Why Now?” and “How To” Primer

Coblentz Patch Duffy & Bass on

Due to increased valuation of public and private equities, coupled with the upcoming end of the sunset provision that allows hedge fund managers to defer taxation on fees earned offshore, there is an increased interest among...more

Troutman Pepper Locke

Locke Lord QuickStudy: New UK Rules on Disguised Investment Management Fees

Troutman Pepper Locke on

On April 6, 2015, the United Kingdom’s taxing authority (HMRC) enacted new rules that are designed to close an investment management fee “loophole” that allowed private equity fund managers to avoid taxes on management fees...more

Troutman Pepper

Private Equity Fees and Expenses

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In This Presentation: - Agenda - Typical Fund Structure - Typical Fund Waterfall - Fund Economics- Nuances - LPA Provisions - Fund Due Diligence - Legal Landscape - PEI...more

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