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Tax Reform Investment Management

K&L Gates LLP

Europe: Fundamental Reform of UK Taxation of Carried Interest

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From 6 April 2026, carry will be redefined and taxed in the United Kingdom as deemed UK trade or business income where investment management services (as redefined) are performed in the UK. The relevant draft legislation was...more

Katten Muchin Rosenman LLP

HMRC Publishes Draft Legislation for New UK Carried Interest Tax Regime

On July 21, 2025, HM Revenue and Customs (HMRC) published the long-awaited draft legislation (Draft Legislation) for the new UK carried interest tax regime (New Regime) that will apply from April 6, 2026. Under the New...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

Akin Gump Strauss Hauer & Feld LLP

From Crackdown to Calibration: The UK’s Evolving Carried Interest Regime

In November, we covered the UK government’s proposal to overhaul the tax treatment of carried interest in the United Kingdom—an effort to close perceived loopholes by shifting carried interest fully into the income tax...more

Troutman Pepper Locke

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

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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

Seward & Kissel LLP

House Tax Bill 2025

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On May 12, 2025, Republicans in the House of Representatives introduced the One, Big, Beautiful Bill of 2025 (the “House Bill”). The House Bill comes out of the House Ways and Means Committee after weeks of internal drafting...more

Proskauer - Tax Talks

The One Big Beautiful Bill: SALT Deduction Workarounds Under Fire

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On May 12, 2025, House Republicans unveiled a comprehensive 389-page package of tax provisions, setting the stage for a significant tax bill to be debated in the coming weeks. Dubbed the “One Big Beautiful Bill,” this...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

ArentFox Schiff

Let It Be…Taxed? The Carried Interest Debate Continues

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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

Cadwalader, Wickersham & Taft LLP

Treasury Delivers Mother Lode of Tax Reporting Rules to the Crypto Industry’s Doorstep

On August 29, 2023, the IRS published detailed proposed regulations addressing digital asset broker reporting requirements (the “Proposed Regulations”). The Proposed Regulations elaborate on the 2021 changes to the Internal...more

Cadwalader, Wickersham & Taft LLP

UK Government Considering Expansion of Investment Transactions List to Include Crypto-Assets

The UK Government has announced a public consultation regarding the possible expansion of the UK’s investment manager exemption (“IME”) to encompass crypto-assets. The IME enables UK-based fund managers to provide...more

Freeman Law

Notable Tax Takeaways from President Biden’s Budget

Freeman Law on

On March 28, 2022, President Joe Biden released his FY 2023 Budget of the U.S. Government (the “Budget”). In a statement regarding the Budget, President Biden stated the following...more

Miller Nash LLP

Today in Tax: The Billionaire Minimum Income Tax and Cryptocurrency Tax Provisions in Biden’s 2023 Budget Proposal

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Brief commentary on recent cases, rulings, notices, and related federal tax guidance. The Billionaire Minimum Income Tax in Biden’s 2023 Budget Proposal - Biden’s proposed “top-up” tax on wealthy individuals would ensure...more

Skadden, Arps, Slate, Meagher & Flom LLP

Increased Funding Would Support IRS Drive To Audit More Partnerships and Wealthy Individuals

More — and more rigorous — IRS examinations are coming. The Biden administration is committed to closing the “tax gap” (the difference between taxes owed and taxes actually paid on time). Increased enforcement efforts are...more

Proskauer Rose LLP

Proskauer’s Second Annual Survey on Trends in Private Credit Markets

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We are delighted to share with you the results from our second annual Trends in Private Credit survey. This year’s survey was conducted via web from January 9th to February 9th 2018. In this report, we will share...more

K&L Gates LLP

Tax Reform and Investment Management: Effect on Registered Investment Companies

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The Tax Cuts and Jobs Act (“Act”) significantly changed U.S. tax federal law. Although the Act does not amend any of the provisions directly affecting the qualification or other taxation of a “regulated investment company”...more

K&L Gates LLP

Tax Reform and Investment Management: Certain International Provisions

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In addition to the very significant changes to the domestic provisions of the Internal Revenue Code (the “Code”), the Tax Cut and Jobs Act (the “Act”) made very significant changes to the taxation of foreign income of U.S....more

K&L Gates LLP

Tax Reform and Investment Management: Initial Observations

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On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the “Act”). While the Act will impact many types of taxpayers, some of the more significant changes are relevant to private funds, investment advisers,...more

Foley Hoag LLP

Tax Reform Impact on Carried Interest for Investment Managers

Foley Hoag LLP on

The federal tax reform legislation that became law on December 22, 2017 contains a provision that will impose a new limitation on investment managers with respect to capital gains derived through carried interests in...more

Cadwalader, Wickersham & Taft LLP

Effects of House Tax Reform Bill on Securitizations and Funds

On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”). The Bill, which is entitled the “Tax Cuts and Jobs Act,” includes significant changes to the...more

Katten Muchin Rosenman LLP

Tax Reform: Hedge Funds/Commodity Funds/Fund Managers

House Republicans released their draft tax bill on November 2, representing their opening bid in the drive to reach agreement on a comprehensive tax reform bill that can be presented to the House for a vote before the...more

Proskauer - Tax Talks

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

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After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

K&L Gates LLP

Committee Report: New Tax System for Managed Investment Trusts

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On 10 March 2016, the Senate Economics Legislation Committee published the Report on the proposed legislation which will introduce a new system for taxing attribution managed investment trusts (AMITs). Committee's Views on...more

Proskauer Rose LLP

UK Summer Budget 2015 – Key Issues for Asset Managers and Non-UK Domiciled Individuals

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On 8th July 2015, the UK Government announced several changes to UK tax legislation that will affect those holding carried interest in fund structures which utilise at least one partnership (including a limited partnership),...more

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