News & Analysis as of

Private Equity Tax Planning Investment Funds

Carey Olsen

Guernsey funds – special considerations for US managers

Carey Olsen on

Guernsey, located in the English Channel, is one of the world’s largest offshore finance centres, with a thriving funds industry. The value of funds under management and administration in Guernsey is US$532bn. Guernsey is an...more

Hogan Lovells

UK carried interest regime: draft legislation confirms scope and conditions

Hogan Lovells on

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

Latham & Watkins LLP on

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

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

A&O Shearman

Navigating private credit in Türkiye

A&O Shearman on

Türkiye is fast emerging as an increasingly attractive destination for private credit providers looking to deploy capital and diversify their portfolios. Despite this growing interest, relative to its size as the seventh...more

Latham & Watkins LLP

Latham Texas Private Funds Breakfast Series Introduction to Continuation Fund Transactions

Latham & Watkins LLP on

This winter, Latham’s Investment Funds Practice delivered an in-depth exploration of continuation fund transactions, offering strategic insights and practical guidance in the latest installment of the Texas Private Funds...more

Hogan Lovells

Carried interest schemes for asset managers

Hogan Lovells on

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

Goodwin

Was Your SIF Set Up Before 2016? Consider a RAIF Conversion While Evaluating the Benefits of Maintaining a SIF

Goodwin on

The Specialised Investment Fund (SIF) regime was established in Luxembourg by the Law of 13 February 2007 (the “SIF Law”). The SIF regime’s purpose was to offer great flexibility on investment scope while structuring and...more

Walkers

Moving to the Channel Islands: A guide for asset managers

Walkers on

Jersey and Guernsey have long been recognised as leading international investment hubs, offering asset managers a compelling mix of professional and lifestyle advantages....more

Walkers

The Channel Islands structures being used for infrastructure assets

Walkers on

We are continuing to see Guernsey and Jersey structures being established for investment into and acquisition of infrastructure assets such as windfarms, network utilities and renewable power....more

Vinson & Elkins LLP

Capital Commitment: A Billion-Plus for American Infrastructure

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Vinson & Elkins Partners Robert Seber, David Peck, and Megan James, counsel to Ridgewood Infrastructure, share the story behind the private equity firm’s latest success and the legal work that went into it....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

Seward & Kissel LLP on

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

Hogan Lovells

Another U.S. IRS Victory in the Self-Employment Tax Arena: Denham Capital Management

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For those keeping score at home, it’s currently two wins for the IRS in as many years, and nada/zilch/zero for the fund managers, at least when it comes to the limited partner exception for self-employment taxes (the “Limited...more

Foley & Lardner LLP

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

Foley & Lardner LLP on

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

Gray Reed

The Basis Matrix: Navigating the Interplay of Sections 743(b) and 734(b)

Gray Reed on

Real estate funds and family offices are two types of investors that often (i) purchase equity interests in partnerships and (ii) make in-kind asset distributions for tax planning purposes. Well advised real estate and family...more

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