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Charitable Split-Interest Trust Planning With Dale Schroeder and Anneke Niemira - Part One
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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
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
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
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
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
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
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
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
The tax treatment of carried interest has long been a subject of political debate. Since 2007, almost annually, the taxation of carried interest has found its way into either proposed legislation or presidential budget...more
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
On February 6, Congressional Republican leaders met with President Donald Trump to address the Trump Administration’s 2025 budget and tax priorities. During that meeting, the Trump Administration proposed to eliminate capital...more
On February 6, 2025, President Donald Trump met with Republican lawmakers to discuss budget priorities, proposing to end carried interest. On the same day, Democrats introduced bills in both the House and the Senate that...more
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
In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more
Below we list some key tax legislative changes that are relevant to new investments in infrastructure projects and that are already in force or have been announced by the government and are under discussion in the National...more
If you acquired or built a senior living facility that is located in an opportunity zone, or are considering doing so, a recent bipartisan bill introduced in Congress proposes making changes to the opportunity zone rules. ...more
After many years of being the target of Congress and the IRS, the Tax Cut and Jobs Act finally succeeded in limiting the beneficial tax treatment of carried interests, at least for some taxpayers. This change will be of...more