News & Analysis as of

Partnerships Investment Management

Skadden, Arps, Slate, Meagher & Flom LLP

The IRS Takes Aim at Basis Adjustments in Partnership Transactions

On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships: In new proposed regulations, the IRS identified several...more

Mayer Brown

Crypto Asset Management: Expansion Roadmap for Managers and Investors (Part 1)

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Asset managers who invest in crypto assets are expanding their footprint as managers of capital for investors. Investors are increasingly seeking out asset managers that have expertise in crypto assets. Likewise, crypto asset...more

Rivkin Radler LLP

New York Can Be Stingy Giving Credit – Resident Tax Credit, That Is

Rivkin Radler LLP on

The Office of the New York State Comptroller just released a new report that examines taxpayer migration trends during the pandemic. The report, which builds on an earlier analysis of pre-pandemic taxpayer migration trends,...more

White & Case LLP

Sector trends - September 2023: Stock Exchanges/Clearing Houses/Trading Venues

White & Case LLP on

Decisive inorganic growth decisions by London Stock Exchange, Deutsche Börse, Nasdaq and Euronext set a furious pace for European trading venue M&A activity....more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Rolls Out Long-Planned Strategy Targeting Large Partnerships and High-Wealth Individual Taxpayers

On September 8, 2023, Internal Revenue Service (IRS) Commissioner Danny Werfel announced the rollout of a coordinated enforcement strategy that will involve audits of returns filed by 75 of the largest partnerships operating...more

Skadden, Arps, Slate, Meagher & Flom LLP

Increased Funding Would Support IRS Drive To Audit More Partnerships and Wealthy Individuals

More — and more rigorous — IRS examinations are coming. The Biden administration is committed to closing the “tax gap” (the difference between taxes owed and taxes actually paid on time). Increased enforcement efforts are...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

McDermott Will & Emery

[Webinar] 2020 Hospital & Health System Innovation Summit - November 11th, 12:00 pm - 2:00 pm EST

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Hospital and Health System Innovation Centers clear the path for healthcare advancement. And in an environment upended by COVID-19, there is no better time for investment in innovation and growth of collaborative partnerships...more

Neal, Gerber & Eisenberg LLP

Fund Managers and Family Offices Get Some Clarity on Carried Interests with Issuance of Proposed Treasury Regulations

On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more

McDermott Will & Emery

Tips for Conducting Effective Due Diligence in an Auction Process

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In today’s highly competitive healthcare environment, investors may find themselves in an auction process where they must conduct due diligence pre-exclusivity. With limited time and mounting pressure, it can be difficult to...more

Akin Gump Strauss Hauer & Feld LLP

BBA Tax Audits: Final Deadline for Designating a U.S. Partnership Representative

• U.S. and non-U.S. investment funds that are required to file, or file, a U.S. partnership tax return (Internal Revenue Service (IRS) Form 1065) are generally subject to a new U.S. partnership audit regime that permits the...more

Allen Matkins

SEC: QOF Interests Are Typically Securities

Allen Matkins on

Yesterday, the staffs of the North American Securities Administrators Association (NASAA) and the Securities and Exchange Commission (SEC) issued a statement describing the "opportunity zone" program created by the Tax Cuts...more

McDermott Will & Emery

Strategies for Maximizing Physician Practice Management Investments

Private equity continues to fuel robust activity in the physician practice management (PPM) sector. Within the last five to seven years, not only have PPMs within traditional areas of medicine proliferated, but new...more

Butler Snow LLP

Trustees, Are You Suffering From “Accountholder” Confusion?

Butler Snow LLP on

Words Matter - So, you’re cruising along in the pre-FATCA/CRS world, providing fiduciary services for your clients, setting up accounts in either the name of the trust, foundation, underlying company or other wealth...more

Williams Mullen

IRS Gets “Bageled” in Tax Court Over Family Office Expenses

Williams Mullen on

A recent case, Lender Management LLC v. Commissioner of Internal Revenue, T.C. Memo. 2017-246, has created a window of opportunity for family offices to restructure their affairs and potentially deduct certain family office...more

Dorsey & Whitney LLP

What Lies Ahead? Q1 2018 Investment Management Regulatory Updates and Reminders

Dorsey & Whitney LLP on

As we start the New Year, we would like to remind our clients of certain regulatory developments and upcoming deadlines for Q1 2018. New Form ADV - The new Form ADV takes a deeper dive by requiring additional...more

Proskauer - Tax Talks

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

Proskauer - Tax Talks on

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

Ballard Spahr LLP

Investment Management Update

Ballard Spahr LLP on

Investment Adviser AXA Wins Excessive Fee Trial - A federal judge in New Jersey has ruled in favor of AXA Equitable Life Insurance Company (AXA Equitable) and its wholly owned subsidiary, AXA Equitable Funds Management...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

Pillsbury Winthrop Shaw Pittman LLP

Proposed Regulations Target Management Fee Waivers

In the Federal Register for July 23, 2015, the Treasury Department published proposed regulations regarding the circumstances under which partnership allocations and distributions will be treated as disguised payments for...more

Morrison & Foerster LLP

Changes in the UK Tax Treatment of Carried Interest

In the recent Summer Budget, the Chancellor announced that with immediate effect, there would be changes to the way that carried interest is taxed. In technical terms, the “base cost shift” which enabled an investment manager...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 4, Issue 6 - June 2013

In This Issue: - Single Charge for Investment Management Services Found Not Subject to New York Sales Tax. - Remote Vendor Not “Doing Business” in New York. - Nonresident Partner’s Loss from 2005...more

Dechert LLP

HM Revenue & Customs Consultation Document Poses Significant Tax Challenges for Investment Management LLPs

Dechert LLP on

On 20th May, HMRC published a consultation document which proposes major changes to the taxation of partnerships in the UK. The consultation is particularly relevant to investment management LLPs – and especially to those...more

Dechert LLP

Financial Services Tax – UK Update from Dechert’s Tax Group - February 2013: FATCA Update – No Duplicate Reporting for Investment...

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Following the execution of an inter-governmental agreement (or “IGA”) with the United States in September 2012 and a consultation exercise which closed in late 2012, HM Revenue & Customs (“HMRC”) recently published draft...more

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