On August 11, 2023, Stamford, Connecticut-based hedge fund manager Point72 Asset Management (“Point72”) filed a petition with the Tax Court contesting the IRS’s position that its owner, billionaire and New York Mets team...more
On June 30, 2023, the United States Department of the Treasury (“Treasury”) published Final Regulations as guidance on the transition from the use of the Interbank Offer Rate (IBOR) to the Secured Overnight Financing Rate...more
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
On July 27, 2022, Senate Majority Leader Chuck Schumer (D-N.Y.) and Senator Joe Manchin (D-W.Va.) released preliminary details of a bill, named the Inflation Reduction Act of 2022, to address climate change, taxes, health...more
8/1/2022
/ Adjusted Gross Income ,
Capital Gains ,
Climate Change ,
Healthcare ,
Holding Periods ,
Interest Rates ,
Internal Revenue Code (IRC) ,
Investment Adviser ,
Price Inflation ,
Proposed Rules ,
U.S. Treasury
As a result of final Treasury Regulations issued by the IRS under Section 1061, fund sponsors should consider investing capital through a commingled fund with other investors as opposed to using its own investment vehicle to...more
Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...more
5/2/2016
/ Affiliates ,
Anti-Inversion Regulations ,
Comment Period ,
Controlled Groups ,
Corporate Taxes ,
Debt ,
IRS ,
Multinationals ,
Parent Corporation ,
Proposed Regulation ,
Related Parties ,
Required Documentation ,
Stocks ,
U.S. Treasury