• The broader application of Section 871(m) has again been delayed, this time until January 1, 2023 and as a result, investment funds with non-U.S. feeders or investors up the chain should generally expect to incur U.S....more
• The latest set of proposed opportunity zone (OZ) regulations (the “2019 proposed regulations”) provide much-needed flexibility with regard to qualified opportunity funds (“OZ Funds”) and expand the types of businesses and...more
5/24/2019
/ Anti-Abuse Rule ,
Capital Gains ,
Carried Interest ,
Debt Financing ,
Intangible Property ,
Investment Funds ,
Opportunity Zones ,
Original Use ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Safe Harbors ,
Tangible Property
• Significant corporate and potential individual tax rate reductions and a 25% individual tax rate on certain “qualified business income” would be introduced (although many fund investors and sponsors would not be eligible...more
11/8/2017
/ Asset Management ,
Blocker Corporations ,
Business Taxes ,
Carried Interest ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
Investment Funds ,
Management Fees ,
Proposed Legislation ,
Reconciliation ,
REIT ,
SALT ,
Tax Cuts ,
Tax Rates ,
Tax Reform ,
UBTI ,
Ways and Means Committee
The Internal Revenue Service (IRS) issued Notice 2013-43 (available here), which delays by six months certain of the timelines during which withholding agents and foreign financial institutions (FFIs) will be required to...more