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Carried Interest

BCLP

Autumn Budget 2024 - What’s the Tax Impact on the Real Estate Sector?

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The real estate sector was not ignored by Budget announcements today. There were no seismic changes – the changes announced were less impactful than the speculation in the weeks preceding the Budget....more

Dechert LLP

Labour Party Manifesto: Key Tax Points for Investment Managers

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The Labour Party Manifesto for the election on 4 July 2024 has now been published. Our key tax takeaways from the manifesto for the asset management sector are as follows:.....more

Goodwin

Approaches Funds Take to Catch-Up Payments Vary by Asset Class

Goodwin on

For a majority of PE, VC, and debt funds, catch-ups are 100%, but they are likely to be less than 100% for real estate and infrastructure funds. In a previous article, we showed that hurdle rates set by private...more

McDermott Will & Emery

[Webinar] Family Office Tax Series: Compensation Strategies - February 27th, 1:00 pm - 2:00 pm EST

McDermott Will & Emery on

Taxes can have a significant impact on family offices, influencing decisions around structure, investing and overall planning strategies. McDermott’s Family Office Tax webinar series explores the latest trends and guidance on...more

Rivkin Radler LLP

Taxes and the 2024 Election: ‘Tis the Season to Plan and Act

Rivkin Radler LLP on

This is The End- I have dreaded the year end for as long as I can remember. As a teenager and then as a young adult I associated the final quarter of the year, and especially the period beginning on Thanksgiving and...more

Rivkin Radler LLP

New York Can Be Stingy Giving Credit – Resident Tax Credit, That Is

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The Office of the New York State Comptroller just released a new report that examines taxpayer migration trends during the pandemic. The report, which builds on an earlier analysis of pre-pandemic taxpayer migration trends,...more

King & Spalding

ILPA Updates Guidance on Continuation Funds

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In May, the Institutional Limited Partners Association (ILPA) introduced its long-awaited guidance on Continuation Funds. LPs have, in ILPA’s view, become “increasingly frustrated” with timeframes and economics in these...more

Lippes Mathias LLP

Should I Create a Life Estate?

Lippes Mathias LLP on

What Is a Life Estate? Life estates are most commonly used with real estate and are created by the owner of the property. If you own your home, you are considered the life estate tenant. As the life estate tenant, you...more

Hogan Lovells

Carried interest: legal challenge to the UK tax treatment

Hogan Lovells on

Recent publicity around the UK taxation of carried interest may, in due course, make it more likely that a UK government would look again at the tax rules around carried interest. ...more

Levenfeld Pearlstein, LLC

Inflation Reduction Act – Channeling The Terminator: I’LL BE BACK

Those of you who followed the drama around the oddly-named Inflation Reduction Act of 2022 will have seen the rise and fall of efforts to change tax laws regarding “carried interests.”...more

Davies Ward Phillips & Vineberg LLP

U.S. Climate Change and Healthcare Bill Moves Democrats’ Tax Policy Forward

The Inflation Reduction Act of 2022 (Act), which was signed into law on August 16, is intended to fight inflation and address climate change. The Act provides for over $360 billion in energy- and climate-related investments,...more

Vinson & Elkins LLP

House Passes Historic Inflation Reduction Act!

Vinson & Elkins LLP on

On August 12, 2022 – a little over two weeks after the legislation was announced and five days after it passed the Senate – the House passed the historic Inflation Reduction Act of 2022 (the “Act”). While the legislation...more

Foley & Lardner LLP

Tax Provisions in the Inflation Reduction Act of 2022

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On August 7, 2022, the Senate passed a major climate, health and tax bill through the budget reconciliation process. The bill, named the Inflation Reduction Act of 2022, is expected to be taken up by the House of...more

Whitman Legal Solutions, LLC

Tax Treatment of Carried Interests Not Likely to Change This Year

Just over a week ago, in Changes to Tax on Carried Interest Would Lead to Conflicts of Interest, I wrote about a proposal in Congress to modify the tax laws relating to carried interests. However, now like Ko-Ko, carried...more

Jackson Walker

Senate Passes Significant Tax Changes Over the Weekend

Jackson Walker on

Over the weekend, the U.S. Senate passed H.R. 5376, the Inflation Reduction Act of 2022 (the “Act”) as part of the fiscal year 2022 budget reconciliation bill. The U.S. House of Representatives will consider the Act this...more

McGlinchey Stafford

Real estate developers can breathe easier: Senate’s Inflation Act does not strangle “promotes”

McGlinchey Stafford on

The United States Senate passed the Inflation Reduction Act of 2022 (Act) on August 7, 2022. As introduced in the Senate, the Act included a provision regarding carried interests (known to real estate developers as...more

Morrison & Foerster LLP

Proposed “Inflation Reduction Act” Could Significantly Curtail Carried Interest Tax Benefits

On July 27, 2022, Senate Majority Leader Chuck Schumer and Senator Joe Manchin announced their agreement on proposed legislation (the “Inflation Reduction Act of 2022” or “Act”) that is expected to be considered by the Senate...more

King & Spalding

Changes to Taxation of Carried Interest in the Inflation Reduction Act of 2022

King & Spalding on

The recently proposed “Inflation Reduction Act of 2022” includes a proposal (the “carried interest proposal”) to amend the rules under section 1061 of the Internal Revenue Code of 1986, as amended (the “Code”) relating to the...more

Eversheds Sutherland (US) LLP

Inflation Reduction Act targets carried interests

On June 27, US Senators Joe Manchin and Chuck Schumer announced proposed legislation referred to as the Inflation Reduction Act of 2022 (the Act). The proposed legislation includes changes that would expand the scope of IRC...more

Paul Hastings LLP

Proposed Legislation Threatens to Upend Carried Interest Rules

Paul Hastings LLP on

As widely reported, on July 27, 2022 Democratic Majority Leader Senator Chuck Schumer and Senator Joe Manchin (D-W.Va) agreed to a reconciliation bill package titled the Inflation Reduction Act of 2022. The bill contains...more

Whitman Legal Solutions, LLC

Changes to Tax on Carried Interests Would Lead to Conflicts of Interest

Politicians are touting a new tax proposal they claim would "close the carried interest loophole." The tax proposal wouldn't eliminate carried interests as implied—it would only extend the holding period from three to five...more

McDermott Will & Emery

Inflation Reduction Act & Long-Term Capital Gain for Carried Interest

OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more

Clark Hill PLC

Congress Proposes Changes to the Taxation of Carried Interest

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On July 27, the Senate reached a deal that would raise taxes on carried interest income earned by investment managers. If enacted, the Inflation Reduction Act of 2022 (the “Act”) would amend the relatively new Section 1061...more

Rivkin Radler LLP

The Schumer-Manchin Proposal To “Eliminate” the Profits Interest

Rivkin Radler LLP on

Summer Break? After the last couple of weeks, I’m looking forward to Congress’s summer vacation. I’m pretty sure our elected representatives feel the same way, though it is unclear at this point when they will be heading...more

Jackson Lewis P.C.

Inflation Reduction Act of 2022 Aims to Close Carried Interest Loophole

Jackson Lewis P.C. on

Earlier this week, Senators Manchin and Schumer reached an agreement securing the former’s support for a tax bill proposed by Senate Democrats entitled the “Inflation Reduction Act of 2022” (the “Act”). Included in the Act...more

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