News & Analysis as of

Partnerships Investment Funds

K&L Gates LLP

Doing Business in Australia

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Australia welcomes new business and foreign investment by providing a strong economy, a stable political environment and a skilled and talented workforce. Our comprehensive guide to Doing Business in Australia has been...more

Gray Reed

The Basis Matrix: Navigating the Interplay of Sections 743(b) and 734(b)

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Real estate funds and family offices are two types of investors that often (i) purchase equity interests in partnerships and (ii) make in-kind asset distributions for tax planning purposes. Well advised real estate and family...more

Cadwalader, Wickersham & Taft LLP

Unlocking the Hybrid October 2023 - Why so Seri(e)ous? Cayman Series Partnerships in Fund Finance Transactions

Funds make use of series partnerships across jurisdictions to allow for segregation of partnership interests, assets, distributions and operations into separate series or classes. A particular quirk of Cayman series...more

Barnea Jaffa Lande & Co.

Default Arrangements in Israeli Investment Funds – Unwritten Provisions in Partnership Agreements

Israeli investment funds are incorporated as limited partnerships under the Israeli Partnerships Ordinance. Investors are “limited partners” and the fund manager (or another corporation acting on its behalf) is the “general...more

Morgan Lewis

Taxpayer Victory in US Tax Court Highlights Need for Properly Structuring Partnership Profits Interests

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A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a...more

Goodwin

Horizon Scan for Private Investment Funds: Key Recent and Expected Funds, Regulatory and Tax Developments to Look Out For - May...

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Welcome to the second edition of our Horizon Scan, where we focus on some of the principal recent and expected developments and changes that we expect to be of interest to those in the non-listed funds sector. We have grouped...more

Nutter McClennen & Fish LLP

Structuring Fund Debt-Financed Investments in S Corporation Businesses to Minimize Ordinary Income to the S Corporation

Partnerships are ineligible S corporation shareholders. So, a partnership cannot acquire shares in an S corporation without terminating that corporation’s S election. However, a partnership can still invest in an S...more

Jackson Lewis P.C.

Carried Interest/Promote in 2022: Action Items for Investment, Private Equity, Real Estate Fund Managers

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Investment, private equity, and real estate fund managers should consider becoming familiar with the complex final regulations on the preferential tax treatment of “carried interest” under Section 1061 of the Internal Revenue...more

BakerHostetler

Crypto Products and Mining Initiatives Launch; Sports and Spirits Firms Embrace Blockchain; US Agencies Seek Crypto Input, Address...

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A well-known digital currency investment services company announced the launch of its first European exchange-traded fund (ETF), according to a press release this week. The ETF, which will be traded on multiple foreign...more

Allen Matkins

Forming Your First Real Estate Fund

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The COVID-19 pandemic has resulted in seismic shifts to the real estate industry over the last year. Shifting preferences and governmental restrictions severely impacted retail, hospitality and commodity office asset classes....more

Manatt, Phelps & Phillips, LLP

[Webinar] Banking and Fintech Transactions: 2020 Forecast - March 25th, 2:00 pm ET

Bank transaction activity has picked up as small and midsize banks look to adjust their business models to the digital economy. Some fintech companies have chosen to acquire or form their own banks. The clash between the new...more

Proskauer Rose LLP

UK Tax Round Up - January 2020

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UK General Tax Developments - Date set for next UK Budget - The first Budget of the new Conservative government will be held on Wednesday 11 March. There has been significant speculation that there will be a major...more

McDermott Will & Emery

Highlights from the Final Opportunity Zone Regulations

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The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more

Proskauer - Tax Talks

Simplification of UK Partnership Tax Reporting for Investment Fund Partnerships

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In the Finance Act 2018, the UK Government enacted a number of changes to the information required in partnership returns that raised the concern of undue and impracticable administrative burden being imposed on UK investment...more

White & Case LLP

In Limited Ruling, Sun Funds Avoid Liability for Portfolio Company Pension Obligations

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First Circuit: Two affiliated funds did not form an implied partnership liable for pension obligations of a portfolio company, but private equity funds can still be subject to controlled group pension liability...more

Latham & Watkins LLP

Investment Funds: Sun Capital Reversal Offers Important Takeaways Regarding Portfolio Company Pension Liabilities

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The First Circuit reverses a lower court decision and finds two Sun Capital private equity funds are not liable for portfolio company’s pension plan liabilities under ERISA. On November 22, 2019, the United States Court of...more

Seyfarth Shaw LLP

First Circuit Rules That Private Equity Funds Are Not Responsible For Portfolio Company Withdrawal Liability

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Seyfarth Synopsis: In a long-awaited decision with significant impact for the private equity industry, in Sun Capital Partners III, LP v. New England Teamsters & Trucking Industry Pension Fund, the United States Court of...more

Skadden, Arps, Slate, Meagher & Flom LLP

Recent Sun Capital Decision Reverses Lower Court's Ruling That Funds Are Liable for a Portfolio Company's Withdrawal Liability

The First Circuit, however, disagreed with the lower court. Analyzing the multi-factor test for establishing partnership status under federal tax court precedent and noting the lack of other formal guidance from regulators or...more

Dechert LLP

A Full House: Proposed Update to Investment Limited Partnership Structure to Further Enhance Ireland’s Alternative Fund Offering

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On 20 June, 2019, Ireland’s government released its proposed Investment Limited Partnerships (Amendment) Bill 2019 (the “Bill”) that will update the Investment Limited Partnership (“ILP”) structure....more

Miles & Stockbridge P.C.

2nd Tranche of OZ Regulations

On April 16, 2019, Treasury issued its second set of proposed regulations (“OZ Regs 2”) regarding Section 14002 of the Internal Revenue Code of 1986, as amended (the “Code”). The OZ Regs 2 are very helpful and answer a...more

Foley & Lardner LLP

A Round Up of Key Trends in Health Care Private Equity Investments

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This conference season, private equity (PE) investors and provider compared notes on the current state of the markets, trends, opportunities and challenges...more

Bracewell LLP

Is the Opportunity Now a Reality? IRS and Treasury Release Second Tranche of Opportunity Zone Regulations

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After months of waiting, the IRS and the Treasury Department have released a second set of proposed regulations (the “Second Tranche”) relating to the opportunity zone provisions enacted as part of the Tax Cuts and Jobs Act...more

Flaster Greenberg PC

Guide to the Surprises Lurking in the QOZ Proposed Regulations

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While mid-April is typically associated by most with Tax Day, this year, April 2019, also became the month the highly awaited second round of Qualified Opportunity Zone Proposed Regulations were issued....more

Verrill

Opportunity Fund Investors Prepare to Zone-In

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Treasury Provides Additional Clarity on Opportunity Zones by Issuing Second Round of Proposed Regulations - On April 17, 2019, the U.S. Department of the Treasury issued its second set of proposed regulations (the “New...more

UB Greensfelder LLP

IRS Issues Long-Awaited Second Round of Opportunity Zone Regulations

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As part of the 2017 Tax Cuts and Jobs Act, Congress added a new provision to the Internal Revenue Code allowing investors to defer capital gains by making investments into Qualified Opportunity Funds (QOFs). However, many...more

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