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Partnerships › Passive Investments › Proposed Regulation

Holland & Hart LLP

Fund Formation and Credit Transfers: Monetizing Tax Credits Using Partnerships

Holland & Hart LLP on

Section 6418 of the Internal Revenue Code (as added by the Inflation Reduction Act of 2022) allows an eligible taxpayer that qualifies for certain clean energy tax credits, including investment tax credits and production tax...more

Fenwick & West LLP

PFIC: What U.S. Investment Funds Should be Particularly Aware of and Newly Proposed Regulations

Fenwick & West LLP on

U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules, which could substantially increase the tax owed on exit for U.S....more

Dechert LLP

IRS Releases Proposed Tax Regulations on PFICs, Including Guidance for Foreign Insurance Corporations and Their Investors

Dechert LLP on

The U.S. Department of the Treasury and the Internal Revenue Service on July 10, 2019, released proposed regulations relating to the tax treatment of investors that own stock of a passive foreign investment company (“PFIC”)...more

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