News & Analysis as of

Taxation Investment Funds Proposed Legislation

Goodwin

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

Goodwin on

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

Latham & Watkins LLP

The UK’s New Regime for Carried Interest Taxation - How the Draft Legislation Stacks Up

Latham & Watkins LLP on

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

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

Paul Hastings LLP on

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

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

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

Ropes & Gray LLP

Impact of Permanent Establishment Reform for Credit Funds

Ropes & Gray LLP on

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

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