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Tax Planning Investment Funds

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

McDermott Will & Schulte

Carried interest in the UK: The new average holding period (AHP) condition for credit funds

The UK tax regime for carried interest is being substantially revised from April 2026. This Alert focuses on one particular aspect: the changes to how credit funds should calculate the average holding period (AHP) of their...more

ASKramer Law

Tax-Loss Harvesting Part III: Investment Strategies

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Taxpayers invest to make money and hope to earn a decent return on their investments. Tax-loss harvesting can be used as part of a taxpayer’s overall investment strategy without affecting investment  returns, while offsetting...more

Cooley LLP

Key Tax Law Changes for Fund Managers Under the One Big Beautiful Bill Act

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The “One Big Beautiful Bill Act” (OBBBA), signed into law on July 4, 2025, brings important changes for investment funds. The OBBBA also omits several anticipated provisions that would have adversely impacted investment...more

Jackson Walker

The One Big Beautiful Bill’s New Qualified Opportunity Zones

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Under the One Big Beautiful Bill Act (the “OBBBA”), the qualified opportunity zone (QOZ) program will no longer sunset on December 31, 2026, as was set to be the case prior to the act’s passage. Instead, the OBBBA makes this...more

Carey Olsen

Guernsey funds – special considerations for US managers

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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

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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

Walkers

Overview of the Cayman Islands Economic Substance requirements

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Each entity incorporated, established or registered in the Cayman Islands must file an annual economic substance notification with the Tax Information Authority (the "TIA"). A "relevant entity" conducting "relevant...more

Troutman Pepper Locke

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

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On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert following the passage by the House of...more

Greenberg Glusker LLP

The Tax Joys of Opportunity Zones

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The 2025 tax bill extends and expands the tax benefits to taxpayers that have capital gain and invest an amount equal to the realized gain to acquire an interest in a “Qualified Opportunity Fund,” which in turn invests in...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

Cadwalader, Wickersham & Taft LLP

UK-Perimeter Tax Rules Under the Spotlight

On 28 April 2025, the UK government launched a consultation (the “Consultation”) on proposed legislation to reform the UK’s transfer pricing (“TP”) and permanent establishment (“PE”) rules, including changes to the investment...more

Cadwalader, Wickersham & Taft LLP

Congress Targets Partnership Disguised Sales and Services

Both the House’s and Senate’s budget bills would clarify that certain rules applicable to disguised payments for services and disguised sales of property between a partner and a partnership under Section 707(a)(2) are...more

Mayer Brown

Subscription Finance: Cascading Pledges

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Cascading pledges are frequently used in subscription finance to avoid legal impediments, avoid tax implications and mitigate prohibited transaction risk under the Employee Retirement Income Security Act of 1974, as amended...more

Morgan Lewis

One Big Beautiful Bill Act Tax Proposals: Select Highlights and Implications

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The US House of Representatives on May 22, 2025 passed the One Big Beautiful Bill Act (the Act), which includes a tax package that would extend certain provisions of the 2017 Tax Cuts and Jobs Act set to expire at the end of...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

Walkers

Thinking ahead: Key considerations for winding up Guernsey investment funds

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The process of winding up a Guernsey fund involves several important considerations that boards, fund managers, investment advisers and administrators must navigate carefully. This article explores six aspects which we...more

Holland & Knight LLP

Independent Sponsors: Section 1202 Qualified Small Business Stock

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The tax benefits conveyed by Section 1202 of the Internal Revenue Code to owners of qualified small business stock (QSBS) have been available to small business owners in some form since Section 1202 was first enacted in 1993....more

DLA Piper

House Committee on Ways and Means Proposed Tax Bill: Key Takeaways

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On May 9, 2025, House Committee on Ways and Means Chairman Jason Smith (R-MO) released a proposed 28-page tax bill, which is scheduled for markup by the House Committee on Ways and Means on May 13, 2025. Below, we highlight...more

A&O Shearman

Navigating private credit in Türkiye

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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

Cadwalader, Wickersham & Taft LLP

Tax Court Calls Bluff on Hedge Fund’s Basket Option Contracts

The Tax Court recently held that a hedge fund’s basket option contracts were in substance tax ownership of the underlying basket securities. The hedge fund, through its affiliated entities, entered into 10 basket option...more

Goodwin

Pillar II in Luxembourg: What Investment Funds Need to Know

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The implementation of the Organisation for Economic Co-operation and Development’s (OECD’s) Pillar II rules in Europe, and in the Luxembourg law on 22 December 2023 (the Pillar II Law) in particular, has been a major...more

Latham & Watkins LLP

Latham Texas Private Funds Breakfast Series Introduction to Continuation Fund Transactions

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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

Mayer Brown

Déductibilité des intérêts portant sur les obligations convertibles : validation de l'utilisation du logiciel Standard et Poor's...

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Par un arrêt du 28 janvier 2025, le Tribunal administratif de Cergy Pontoise (n°2100034) approuve l'utilisation du logiciel Standard et Poor's Capital IQ pour justifier le taux d'intérêt d'obligations convertibles....more

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