Net Asset Value (NAV)-based financing facilities (“NAV Facilities”) continue to proliferate in private equity. In response, the Institutional Limited Partners Association (ILPA) released comprehensive new guidance making the...more
The U.S. Securities and Exchange Commission (SEC) is engaged in new litigation following the introduction of the Private Fund Adviser (PFA) Rule. Designed to bolster transparency and competition within the private funds...more
The Securities and Exchange Commission (SEC) has adopted the long awaited “Private Fund Adviser Rule” (the “PFA”). The proposed PFA was introduced on February 9, 2022 (“Proposed Rule”), and the SEC has been working with the...more
8/25/2023
/ Disclosure Requirements ,
Final Rules ,
Investment ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Management ,
Investors ,
Private Funds ,
Proposed Rules ,
Registered Investment Advisors ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
Seyfarth Synopsis: On December 29, 2020, the Internal Revenue Service issued Revenue Procedure 2021-9 (the “Procedure”), which provides a safe harbor that allows the owner or operator of certain senior living facilities (a...more
The proposed Tax Cuts and Jobs Act released by the House of Representatives on November 2, 2017 calls into question the position long taken by government pension plans that they are exempt from the unrelated business income...more
Seyfarth Synopsis: On October 13, 2016 the IRS and Treasury Department published over 500 pages of final and temporary regulations under Code Section 385 (the “Final Regulations”). Drafted to curtail tax benefits accrued by...more
11/7/2016
/ Cross-Border Transactions ,
Debt Financing ,
Debt-Equity ,
Disguised Sales ,
Disregarded Entities ,
Foreign Subsidiaries ,
Inversion ,
IRS ,
Multinationals ,
Parent Corporation ,
Partnerships ,
Proposed Regulation ,
Reclassification Rules ,
Recordkeeping Requirements ,
REIT ,
RICs ,
S-Corporation ,
Subsidiaries ,
U.S. Treasury
Seyfarth Synopsis: On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other partnership tax issues, including “bottom-dollar”...more