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Taxation 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

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

Herbert Smith Freehills Kramer

Luxembourg: Explaining the New Carried Interest Tax Regime

On 24 July 2025, the Luxembourg government introduced Bill No. 8590 (the Bill), which proposes a new competitive carried interest tax regime with the stated objectives being: to create a legal framework that fosters the...more

Goodwin

Carried Interest 2.0: Luxembourg Modernises Its Tax Treatment for Fund Managers

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On 24 July 2025, a draft bill (the Bill) proposing significant amendments to the law of 4 December 1967 on income tax and the law of 12 July 2013 on alternative investment fund managers (AIFMs) was submitted to the Luxembourg...more

Herbert Smith Freehills Kramer

LP-led Fund Secondaries – What You Need to Know

Fund secondaries transactions have grown enormously over the last 20 years or so. Recently, funds have been under pressure to return capital to investors in the context of a range of market constraints on traditional exit...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

DLA Piper

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

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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

Cadwalader, Wickersham & Taft LLP

Quarter End Fireworks, June 2025 - In the News: (Potentially) Taking Revenge Through Tax

As we power through what remains of this quarter, working to get deals closed before quarter end next week, you may have noticed some additional (and new!) blacklining in the tax section of your credit agreement thanks to a...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

Paul Hastings LLP

Section 899 of the One Big Beautiful Bill — Focus on Tax and Private Funds

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On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...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

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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

Carey Olsen

Why the Cayman Islands continues to be a popular jurisdiction for offshore funds

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Over the past 25 years, the Cayman Islands have established themselves as a leading jurisdiction for alternative investment funds, with nearly 13,000 regulated open-ended funds and over 17,000 regulated closed-ended funds. As...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

Proskauer Rose LLP

UK Tax Round Up - April 2025

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Welcome to April’s edition of our UK Tax Round Up. While this month has been quiet on the case law front, there have been a number of HMRC announcements and updates to prior published guidance along with published responses...more

Ropes & Gray LLP

Impact of Permanent Establishment Reform for Credit Funds

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On 28 April, the UK Government produced draft legislation for consultation as the latest step in the reform of UK rules on transfer pricing, permanent establishments and diverted profits tax. From an asset management...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

Hogan Lovells

Carried interest schemes for asset managers

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During the last decade, the shape and source of capital flows and investment have fundamentally shifted. Private capital continues to flow into all asset classes including real estate, infrastructure, private credit, and...more

Cadwalader, Wickersham & Taft LLP

The New UK Reserved Investor Fund: RIFs and QAHCs Create an Ambitious UK Structuring Toolkit

Introduction - After a long gestation, the much heralded new UK fund structure, the Reserved Investor Fund (“RIF”) is finally expected to be available from 19 March 2025....more

Eversheds Sutherland (US) LLP

SEC releases 2025 Names Rule FAQs

On January 8, 2025, the staff (Staff) of the Securities and Exchange Commission’s (SEC) Division of Investment Management (IM) released the 2025 Names Rule FAQs (2025 FAQs) related to the amendment of Rule 35d-1 (Names Rule)...more

Carey Olsen

GLI Cayman Islands blockchain and cryptocurrency regulation 2025, seventh edition

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Regulatory clarity in the digital assets and crypto space continues to be a moving target. Yet, the interest among policymakers and regulators worldwide has never been more pronounced. In the United States, 2024 was a pivotal...more

White & Case LLP

Capital Markets, Securitization and Debt Investment Fund Platforms: Important Luxembourg Tax Legislation Update

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As the end of 2024 draws to a close, Luxembourg aims to introduce an interesting technical update that may globally be of interest for our clients with structures in Luxembourg. On 11 December 2024, the Luxembourg...more

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