The guidance shows Treasury Regulations will ease administrative challenges and exclude certain transfers from the new withholding regime.
Key Points:
..Taxpayers can deliver IRS Form W-9 or an affidavit to establish...more
Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context.
Key Points:
..The legislation alters fundamental aspects of US business taxation...more
1/11/2018
/ Corporate Taxes ,
Energy Sector ,
Mortgage REITS ,
Multinationals ,
Net Operating Losses ,
Private Investment Funds ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
Aspects of the current proposals could significantly alter the US taxation of investment funds, sponsors, and investors.
Key Points:
..Major changes to US tax laws on business tax rates, interest deductibility, and...more
Certain arrangements would be recharacterized as ordinary income, rather than as distributive shares of partnership income.
On July 22, 2015, the US Treasury Department and the US Internal Revenue Service (IRS) released...more
Changes in fee terms as well as new guidance regarding GAAP consolidation and potential future tax developments can impact how fund sponsors structure and negotiate their investment vehicles.
Despite a slight downturn in...more