Under current (post-2017) federal income tax law, long-term capital gain allocated to or realized by a non-corporate recipient of a promote or other performance-based allocation (a "Carried Interest") in the investment...more
On October 31, the Internal Revenue Service (IRS) released proposed regulations (the "Proposed Regulations") under Section 956 that could substantially increase the collateral packages made available by US corporate borrowers...more
11/6/2018
/ Controlled Foreign Corporations ,
Corporate Financing ,
Dividends ,
Domestic Corporations ,
GILTI tax ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Section 956 ,
Shareholders ,
Subsidiaries ,
U.S. Treasury
House Republicans released their draft tax bill on November 2, representing their opening bid in the drive to reach agreement on a comprehensive tax reform bill that can be presented to the House for a vote before the...more
11/9/2017
/ Alternative Minimum Tax ,
Corporate Taxes ,
Deferred Compensation ,
Hedge Funds ,
Income Taxes ,
Investment Funds ,
Investment Management ,
Pass-Through Entities ,
Proposed Legislation ,
Tax Rates ,
Tax Reform