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Tax Reform Investment Funds

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

Jackson Walker

The One Big Beautiful Bill’s New Qualified Opportunity Zones

Jackson Walker on

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

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

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

DLA Piper

One Big Beautiful Bill Act: Top Points for the Investment Funds Industry

DLA Piper on

President Donald J. Trump signed the legislation commonly known as the “One Big Beautiful Bill” (Tax Act) into law on July 4, 2025. We explore five key takeaways for fund sponsors, investors, and the broader asset management...more

Foley & Lardner LLP

One Big Beautiful Bill Act – Tax Considerations for Investment Funds

Foley & Lardner LLP on

On July 4, 2025, President Donald Trump signed into law extensive tax legislation as part of the One Big Beautiful Bill Act (OBBBA) that will impact the investment fund industry.  Perhaps one of the most important aspects...more

Sullivan & Worcester

"One Big Beautiful Bill Act" Enshrines Opportunity Zone Provisions

Sullivan & Worcester on

On July 4, 2025, President Trump signed the "One Big Beautiful Bill Act" (the “OBBBA”), which contains amendments to sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code (the “Original Statute”)—the provisions that...more

Seward & Kissel LLP

A Big Beautiful Law: Congress Passes Trump’s Tax Reform Package

Seward & Kissel LLP on

This Memorandum continues our analysis of the current U.S. federal tax reform process. Today, the House of Representative passed the Senate’s version of the One Big, Beautiful Bill (the “Senate Tax Bill”). The Senate Tax Bill...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

DLA Piper

Senate Tax Bill: Key Points for the Investment Funds Industry

DLA Piper on

The US Senate released a draft tax bill (Senate Tax Bill) on June 16, 2025. We explore five key takeaways for fund sponsors, investors, and the broader asset management community, with a focus on how the Senate Tax Bill...more

Morgan Lewis

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

Morgan Lewis on

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

Proskauer - Tax Talks

UK Government Carried Interest Tax Reforms Consultation Process: No New Conditions, Territorial Limits Clarified

Proskauer - Tax Talks on

June 2025 – The UK Government has published its response to the consultation on its proposal to change the tax treatment of carried interest, confirming the expected final shape of the new regime which will take effect from...more

Fox Rothschild LLP

Changes in Washington State Tax Law Will Impact Businesses

Fox Rothschild LLP on

Washington recently enacted major tax law changes that will affect many businesses operating in the state. Here’s what you need to know: Changes to the Definition of Incidental Investment Income - Washington law now...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

Troutman Pepper Locke on

On May 22, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). The BBB proposes amendments to the Internal Revenue Code (the Code) that could have...more

Goodwin

UK Government announces update on new carried interest tax regime

Goodwin on

On June 5, 2025, the UK Government announced the result of their recent consultation process regarding their plans to bring carried interest within the income tax regime from April 2026, subject to an effective tax rate of...more

Proskauer - Tax Talks

Proposed Changes to Interest Rate Tax Treatment for RICs

Proskauer - Tax Talks on

The One Big Beautiful Bill Act (the “OBBBA“), passed by the U.S. House of Representatives (the “House“) on May 22, 2025, is a comprehensive legislative package that seeks to implement sweeping reforms in tax policy,...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for the Real Estate Industry

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

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

Eversheds Sutherland (US) LLP

The One Big Beautiful Bill’s impact on investments in BDCs

On May 14, 2025, the House Ways and Means Committee approved the so-called “One Big Beautiful Bill” (Bill). We have issued several other alerts regarding the Bill. Among other tax provisions, the Bill includes two provisions...more

DLA Piper

House Passes Sweeping Tax Bill: Top Points for the Investment Funds Industry

DLA Piper on

On May 22, 2025, the House of Representatives passed a tax bill with some limited amendments (House Tax Bill). The House Tax Bill will now head to the Senate, where additional amendments could be made. Below, we outline five...more

DLA Piper

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

DLA Piper on

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

Skadden, Arps, Slate, Meagher & Flom LLP

UK Government Targets Reform of the Investment Manager Exemption

On 28 April 2025, the UK government published draft legislative amendments to: - Align the UK’s domestic tax rules on permanent establishments (PE) with the 2017 Organisation for Economic Co-operation and Development (OECD)...more

McDermott Will & Schulte

Lawmakers Revisit Tax Treatment of Carried Interest

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

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

ArentFox Schiff

Let It Be…Taxed? The Carried Interest Debate Continues

ArentFox Schiff on

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

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