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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

ASKramer Law

Tax-Loss Harvesting Part II: The Wash Sales Rule

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At the beginning of this series, I mentioned briefly that taxpayers can use tax-loss harvesting approaches in tandem with a number of investment strategies, which we will go into in more detail in Part III. Many of these...more

Allen Matkins

Bonus Depreciation Is Back! And Other Big Beautiful Taxes

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On Friday, July 4, 2025, President Trump signed into law the Reconciliation Bill commonly known as the One Big Beautiful Bill Act (OBBBA). Broadly speaking, the OBBBA extends and makes permanent many provisions enacted by the...more

BCLP

Transforming Saudi Arabia's Hotel Industry: Recent Licensing Reforms

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Saudi Arabia is ambitiously working towards its 2030 goals, striving to be investor-friendly while upholding transparency, accountability, and creating more opportunities for its local population. This vision has brought...more

Rivkin Radler LLP

Three Big Beautiful M&A Takeaways

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It hasn’t taken long for the business world to start unpacking the implications of the newly passed One Big Beautiful Bill Act (OBBBA). While media coverage has mostly centered on its impact on individual taxpayers and the...more

Mintz - Tax Viewpoints

QSBS Benefits Expanded Under One Big Beautiful Bill Act

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On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (OBBBA), which included revisions to Section[1] 1202 for “qualified small business stock” (QSBS) unchanged from those initially introduced in the...more

Fox Rothschild LLP

Senate Sidelines Tax on Litigation Finance, But the Fight Goes On

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For now, litigation finance funders can exhale. A proposed tax on profits — initially 40.8%, later revised to 31.8% — has been stripped from the Senate’s sweeping tax and spending bill, dubbed the “One Big Beautiful Bill.” ...more

Vinson & Elkins LLP

Senate Draft Tax Provisions Impacting REITs and Foreign Investors

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On June 16, 2025, the Senate Finance Committee released its draft tax title for inclusion in the Senate’s version of the budget reconciliation bill, known as the “One Big Beautiful Bill Act” (the “OBBBA”). While the Senate...more

A&O Shearman

The FASTER Directive—where are we now?

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After years of negotiation and technical debate, the European Union’s Faster and Safer Tax Relief of Excess Withholding Taxes Directive (“FASTER Directive”)—aimed at streamlining and harmonizing withholding tax (WHT) relief...more

Orrick, Herrington & Sutcliffe LLP

Senate Bill Unexpectedly Proposes Significant Expansion of QSBS Benefits

On June 16, 2025, the Senate Finance Committee introduced a bill that would significantly expand the benefits available for qualified small business stock (QSBS). The expanded QSBS benefits apply to stock acquired after the...more

Seward & Kissel LLP

Should you call 911 about Section 899?

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On May 22, 2025, the House of Representatives passed by a one-vote margin the “One Big Beautiful Bill Act” (the “House Bill”), which has now moved to the Senate for consideration. This Memorandum discusses the House Bill’s...more

Proskauer - Tax Talks

Senator Tillis Introduced a Bill Taxing Proceeds of Litigation Financing Agreements

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Senator Thom Tillis introduced a bill (called the “Tackling Predatory Litigation Funding Act”) that would impose additional significant taxes on litigation funding investments. Rep. Kevin Hern (R-OH) introduced a similar bill...more

McDermott Will & Schulte

The Proposed US Tax Regime for Non-US Investors and Companies

On May 22, 2025, the US House of Representatives narrowly passed a sweeping $3.8 trillion tax reconciliation package known as the One Big Beautiful Bill Act. The legislation now moves to the US Senate, where significant...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

Warner Norcross + Judd

Diversification and Tax Savings with a 1031 UPREIT

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A 1031 UPREIT (Umbrella Partnership Real Estate Investment Trust) transaction allows real estate investors to exchange property on a tax-deferred basis under IRS Section 1031 while gaining diversification and liquidity by...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

Wilson Sonsini Goodrich & Rosati

The Non-U.S. Start-Up’s Guide to Navigating the U.S. Tax Implications of U.S. VC Investment

U.S. start-up investors are increasingly looking overseas for investment opportunities. As U.S. investment in UK and other non-U.S. start-ups rises, founders of those start-ups should be aware of the potential impact of the...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

McDermott Will & Schulte

Exit tax for investement shares

Anyone who moves out of Germany and has investment shares or transfers them outside of Germany will have to pay taxes – even if the shares are not sold. Private investors in investment funds will have to pay taxes in the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Navigating Inbound M&A in India: An Overview

The inbound M&A landscape in India has been experiencing a significant surge of global interest over the past couple of years. While M&A activity globally has cooled, India has emerged as a destination of choice for companies...more

White & Case LLP

Luxembourg Tax Update: Key Takeaways from Prime Minister Luc Frieden’s State of the Nation Address

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In his State of the Nation Address on June 11, 2024, Luxembourg Prime Minister Luc Frieden introduced several significant fiscal policy initiatives aimed at enhancing the country’s attractiveness to international businesses...more

Walkers

Ireland | Chambers 2024 Global Practice Guide on Securitisation

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1. Specific Financial Asset Types - 1.1 Common Financial Assets - A wide range of asset classes have been securitised by Irish special purpose entities (SPEs): residential mortgages; commercial mortgages; auto loans;...more

McDermott Will & Schulte

Cross-Border M&A Comparison Table

Cross-border deals are complex and require mastery of multiple disciplines with unique considerations in different regions. Review our table comparing cross-border deal considerations for various topics across the United...more

Morrison & Foerster LLP

Marketing Private Funds to U.S. Investors — A Practical Guide for Asia-Based Managers

As the private equity (“PE”) and venture capital (“VC”) funds industry grows and matures in Asia, managers are increasingly looking to market interests in their funds to U.S.-based investors. However, many Asia-based managers...more

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