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Tax Reform Tax Planning Carried Interest Tax Rates

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

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Cadwalader, Wickersham & Taft LLP

A Look at the House Ways and Means Committee’s Tax Proposals

I. Introduction - On September 15, 2021, the House Ways and Means Committee approved tax provisions for proposed inclusion in the Build Back Better Act (the BBBA). If enacted in their current form, the proposals would,...more

Polsinelli

The House Ways and Means Committee Finally Provides Draft Legislative Language for the Tax Changes First Set Forth in President...

Polsinelli on

In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. On May 28, 2021, the United State Department of Treasury issued a report entitled “General Explanation of...more

Burr & Forman

Summary of Proposed 2021 Federal Tax Law Changes

Burr & Forman on

President Biden has proposed major changes to the Federal tax laws, some of which are sought to be effective earlier in 2021 (i.e., we are already operating under these changes, if they later become adopted), as compared to...more

Polsinelli

A Summary of Potential Tax Increases That Would Occur Under the Proposed American Families Plan

Polsinelli on

On April 28, 2021, the White House issued a fact sheet which set forth some additional details on the tax increase proposals contained in President Biden’s “American Families Plan.” ...more

Cadwalader, Wickersham & Taft LLP

Biden Tax Proposals to Pay for the American Families Plan

On April 28, 2021, President Biden announced the American Families Plan, a $1.8 trillion proposal that would fund a number of education and childcare projects....more

Lowndes

Biden Proposes Tax Hike on Businesses and High-Income Individuals

Lowndes on

Over the last month, President Biden has discussed various tax proposals that will increase income taxes on businesses and high-income individuals. In the last week, we have learned more about what some of those proposals...more

Morgan Lewis

Tax Reform on the Horizon: Current Developments and Updates

Morgan Lewis on

With the recent passage of the COVID-19 stimulus package, President Joseph R. Biden, his administration, and Congress have turned their attention to long-term economic recovery, deficit reduction, and tax reform. ...more

Cadwalader, Wickersham & Taft LLP

Carried Interests in the Crosshairs (Again)

Democrats have proposed a bill to tax carried interests at ordinary income rates. Under current law, fund managers generally recognize income or gain in respect of their carried interests only when the fund sells assets that...more

Cadwalader, Wickersham & Taft LLP

IRS Proposes Carried Interest Regulations

On July 31, 2020, the IRS and Treasury issued proposed regulations under section 1061 of the tax code. Section 1061 imposes a three-year holding period as a precondition to recognizing long-term capital gains on carried...more

Herbert Smith Freehills Kramer

Final Treasury Regulations Issued Addressing the Application of Section 1061 to Carried Interests (UPDATED)

On Jan. 8, 2021, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued final regulations (Final Regulations) (T.D. 9945) governing the treatment of “carried interests” (also referred...more

Lowndes

Tax Cut and Jobs Act Limits Benefit of Carried Interest

Lowndes on

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

Orrick, Herrington & Sutcliffe LLP

Private Equity Fund Taxation Post-Tax Reform: What Really Changed?

Congress has passed the tax reform bill, known as the “Tax Cuts and Jobs Act” (the “Act”), and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law, many of which will...more

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