News & Analysis as of

U.S. Treasury Investment Funds

Cozen O'Connor

Stablecoins: Navigating the Money Transmitter Minefield & Forthcoming Federal Regulatory Frameworks

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As digital assets gain traction across financial markets, stablecoins—cryptocurrencies pegged to fiat currencies like the U.S. dollar—are emerging as a practical medium for capital contributions, settlements, and liquidity...more

Morgan Lewis

OFAC Action Shows Risk of Not Recognizing That ‘Property Interests’ Include ‘Any Interest Whatsoever’

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The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) fined GVA Capital Ltd. $215 million, primarily for violating the Ukraine/Russia-related sanctions regulations, when GVA mistakenly concluded that it...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

Rivkin Radler LLP

The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?

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An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more

Torres Trade Law, PLLC

Outbound enforcement has started; Treasury contacting U.S. investors

Even though the Trump administration is reviewing the outbound foreign investment review regime, enforcement has begun. We’ve now heard multiple reports that the Treasury Department is reaching out to U.S. venture capital and...more

Paul Hastings LLP

Daily Financial Regulation Update -- Thursday, April 17, 2025

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April 16, 2025 - The U.S. Department of the Treasury released Treasury International Capital (TIC) data for February 2025. The next release, which will report on data for March 2025, is scheduled for May 16, 2025....more

McDermott Will & Emery

Lawmakers Revisit Tax Treatment of Carried Interest

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The tax treatment of carried interest has long been a subject of political debate. Since 2007, almost annually, the taxation of carried interest has found its way into either proposed legislation or presidential budget...more

Akin Gump Strauss Hauer & Feld LLP

A Plan for Establishing a United States Sovereign Wealth Fund

Establishes a sovereign wealth fund to "promote fiscal sustainability, lessen the burden of taxes on American families and small businesses, establish economic security for future generations, and promote United States...more

Morgan Lewis

Private Funds Year in Review: Key Tax Developments That Shaped the Industry in 2024

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In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more

Fox Rothschild LLP

Investments in Chinese Technology Companies Limited by New US Outbound Investment Rule

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U.S. investors interested in investing in advanced Chinese technology companies may now be constrained by the U.S. Government’s first-ever outbound investment rule (Final Rule) which took effect on Jan. 2, 2025. The Final...more

DLA Piper

Treasury Finalizes Rule Restricting US Outbound Investment in China, Including Hong Kong and Macau

DLA Piper on

On October 28, 2024, the US Treasury Department announced the Final Outbound Investment Rule implementing President Joe Biden’s August 2023 “Outbound Order” (Executive Order 14105). The Outbound Order and associated Final...more

Akin Gump Strauss Hauer & Feld LLP

Form SHL: Reports by US Issuers and Others on Foreign Ownership Due August 30, 2024

The U.S. Department of the Treasury requires U.S. issuers—including U.S.-domiciled investment funds1—to report foreign residents’ holdings of U.S. securities every five years on its Treasury International Capital (TIC) Form...more

Wiley Rein LLP

Treasury Issues Draft Regulations for Outbound Investment Security Program; Comments Due August 4

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An August 4 deadline is fast approaching for comments to the U.S. Department of the Treasury’s Notice of Proposed Rulemaking (NPRM) that was issued June 21. The NPRM will restrict, for national security purposes, specific...more

McDermott Will & Emery

The Domestic Content Bonus Credit’s Promising New Safe Harbor

McDermott Will & Emery on

On May 16, 2024, the Internal Revenue Service (IRS) published Notice 2024-41 (Notice), which modifies Notice 2023-38 (Prior Notice) by providing a new elective safe harbor (Safe Harbor) that will allow taxpayers to use...more

Latham & Watkins LLP

Final Carried Interest Regulations: Key Takeaways for Private Fund Sponsors

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While the final regulations simplify key exceptions and contain favorable changes, ambiguity continues for investment fund managers. On January 7, 2021, the US Treasury Department and Internal Revenue Service (together,...more

Herbert Smith Freehills Kramer

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

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

Morrison & Foerster LLP

IRS Rules That Impact Investment Fund Is Not Charitable Activity

Over the last decade, impact investing has become a significant focus of many nonprofits, just as it has captured the attention of investors who care about social benefit or environmental results as much as financial results....more

Tonkon Torp LLP

Top Three Investor-Friendly Rules From The Newest IRS Opportunity Zone Notice

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The IRS issued Notice 2020-39 on June 5, 2020 in response to the COVID-19 pandemic, which extended several deadlines applicable to Opportunity Zone investments. •First, investors get more time to invest eligible gains into a...more

Weintraub Tobin

Opportunity Zone Funds And Investors Get Relief In Light Of COVID-19

Weintraub Tobin on

On June 4, 2020, the Internal Revenue Service published Notice 2020-39 (Notice) which provides relief to qualified opportunity funds (QOFs) and their investors in light of the COVID-19 pandemic. Here is a summary, and more...more

Tarter Krinsky & Drogin LLP

Internal Revenue Service Announces Relief For Qualified Opportunity Zone Investors

On June 4, 2020, the Internal Revenue Service issued Notice 2020-39, which is available here. Notice 2020-39 provides temporary relief to qualified opportunity funds (QOFs) and their investors as a result of the COVID-19...more

Morrison & Foerster LLP

CFIUS Filing Fees Become Reality

The U.S. Department of the Treasury (“Treasury”) announced that on Friday, May 1, 2020, the first-ever filing fees will become effective for joint voluntary notices submitted to the Committee on Foreign Investment in the...more

Latham & Watkins LLP

How Final CFIUS Regulations Will Impact Technology Companies and Investors

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The Final Rules clarify requirements for foreign investments, including those transactions subject to CFIUS review and filing. On February 13, 2020, two Final Rules published by the US Treasury Department implementing...more

Seyfarth Shaw LLP

Final CFIUS Regulations Became Effective in February 2020

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February 13, 2020 was the effective date (the “Effective Date”) for final regulations issued by the U.S. Department of the Treasury (“Treasury”) on behalf of the Committee on Foreign Investment in the United States (“CFIUS”)....more

Miller Canfield

CFIUS Review Authority Expands

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New U.S. Treasury rules expanding the jurisdiction of the Committee on Foreign Investment in the United States (CFIUS) to review foreign direct investment in the United States take effect on Feb. 13. Our summary of the new...more

Seyfarth Shaw LLP

[Event] Treasury Issues Final CFIUS Rules: How Are Transactions With Foreign Parties Affected? - February 27th, New York, NY

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This program, co-sponsored by Seyfarth and Kroll, a division of Duff & Phelps, will bring into sharper focus the application of new regulations issued by Treasury on behalf of the Committee on Foreign Investment in the United...more

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