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Proposed Changes to Code Section ‎‎1061 Contemplate Significant Changes for Real Estate Funds ‎and Developers

The “Inflation Reduction Act of 2022” recently announced by Senators Manchin and Shumer to be added to the 2022 Budget Reconciliation bill proposes several significant changes to Section 1061 of the Internal Revenue Code of...more

Making the Case for Interval and Tender Offer Funds – Hedge Fund and Private Equity Sponsors Can Increase Their Investor Base and...

Introduction - We often hear from hedge fund and private equity sponsors that private funds are too limiting for their capital formation needs. Private funds are collective investment vehicles that rely on the Section...more

IRS Issues Carried Interest Guidance

On July 31, 2020, the Internal Revenue Service and the U.S. Treasury Department issued Proposed Treasury Regulations (the “Proposed Regs”) providing guidance under the “carried interest” rules of Section 1061 of the Internal...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn – “C” Corporation Considerations Supplement

The discussion in this Quick Study Supplement outlines select federal income tax issues “C” corporation borrowers may face in debt restructurings. As noted in our debt restructuring overview Quick Study, a borrower generally...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn – Lender Considerations Supplement

Distressed economic climates can produce unique circumstances for a lender. As a borrower defaults on payments or breaches financial covenants, a lender may reexamine its tax reporting around the borrower’s debt (e.g.,...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn – Partnership Considerations Supplement

The discussion in this Quick Study Supplement outlines select federal income tax issues partnership borrowers may face in debt restructurings. As noted in our debt restructuring overview Quick Study, a borrower generally...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn – “S” Corporation Considerations Supplement

The discussion in this Quick Study Supplement outlines select federal income tax issues “S” corporation borrowers may face in debt restructurings.1 As noted in our debt restructuring overview Quick Study, a borrower generally...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn

As the economic impact of COVID-19 continues to evolve, many businesses are looking to restructure their debt to help navigate through the crisis. In the past several weeks, lenders have been inundated with such requests,...more

UPDATE: CARES Act Guide: Overview of Key Business Tax Provisions

On March 27, 2020, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act or the “CARES Act”, into law. The CARES Act will provide significant financial relief to individuals and small businesses,...more

Federal and State Governments Begin to Provide Economic Assistance via Tax Relief in the Face of COVID-19 Economy Disruptions

Updated on March 20, 2020, 9:00 PM CDT - U.S. Treasury and States Tax Authorities Extend Due Dates - On March 20, 2020, the U.S. Treasury expanded taxpayer relief by extending the filing date by 90 days for Federal income...more

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