Podcast: Credit Funds: The Benefits, Challenges and Applications of Treaty Fund Structures When Investing in Credit
Bill on Bankruptcy: Big Time Lawyers Pricing Themselves Out
ファンドの 投資家 がファンドに対して償還 請求権を有するオープンエンド型ファンドは、 流動性 のある 資産に投資するヘッジファンド等ファンド に適している一方、プライベートエクイティ、ベンチャーキャピタル、不動産等の非流動資産に投資するファンドは、投資が実現するまでにより多くの時間を必要とし、クローズドエンド型ストラクチャーが適しています。...more
Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more
With the recent release of the “Pandora Papers,” renewed attention is focused on corporate ownership transparency. Earlier this year, Congress passed the Corporate Transparency Act (“CTA”). The CTA was enacted to combat the...more
In this series of articles we consider two of the more common requests we see in terms of fund structuring options: Multi-Class Funds, and Hybrid Funds. This second article in the series will consider Hybrid Funds....more
In this series of articles we consider two of the more common requests we see in terms of fund structuring options: Multi-Class Funds, and Hybrid Funds. This first article in the series will consider Multi-Class Funds. Hybrid...more
Code section 965 establishes a transition tax (the “Transition Tax”), which applies to U.S. corporations (and in certain cases, U.S. partnerships and individuals) having control over unrepatriated offshore earnings as of the...more
On August 1, 2018, the Internal Revenue Service and the Department of the Treasury issued proposed regulations on the Section 965 transition tax, which was enacted under the Tax Cuts and Jobs Act. Section 965 levies a...more
In a recent news conference President Obama addressed rules and proposed regulations announced Thursday intended to help the U.S. fight tax evasion and other crimes connected to anonymous offshore companies and accounts. The...more
The Internal Revenue Service (IRS) recently announced “major changes” to its offshore compliance programs, including the Streamlined Filing Compliance Procedures (Streamlined Procedures), the delinquent international...more