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Private Equity › Partnerships › Limited Liability Company (LLC)

Opportune LLP

Exploring Profit Interests: Accounting & Valuation…

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Executives at both public and private companies commonly receive performance-based incentives. The objective is to link compensation closely to a firm's financial results. These performance-based incentives can take many...more

Troutman Pepper

Rolling Over and Section 704(c); What’s the Big Deal? — Part 4: The Remedial Method

Troutman Pepper on

In our continuing series on Section 704(c) of the Internal Revenue Code (the Code) we discuss the application of the remedial method to correct for distortions caused by the ceiling rule. As previously discussed, when the tax...more

Troutman Pepper

Rolling Over and Section 704(c); What's the Big Deal? — Part 2: The Traditional Method

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In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner. As...more

Rivkin Radler LLP

New York’s Pass-Through Entity Tax, F Reorgs, and the Sale of An Electing S Corp

Rivkin Radler LLP on

Timing- I had planned to post this piece during the third week of December, a day or so after the exchange between Senator Manchin and the White House sealed the fate of the Build Back Better plan, at least in its current...more

Rivkin Radler LLP

Selling to Private Equity? Maybe You Should “F Reorg” First

Rivkin Radler LLP on

Having Fun? Hope you had a decent weekend. Perhaps you did something interesting, maybe even fun, like some end-of-season apple picking? Or maybe you had a cider donut with some hot coffee at a farm stand you stumbled upon...more

Kramer Levin Naftalis & Frankel LLP

Proposed Tax Law Amendments and Tax Increases May Impact Private Equity and M&A Deals

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The House Ways and Means Committee recently released legislative proposals as part of the “Build Back Better” reconciliation legislation that the committee is currently developing (the Proposed Legislation). The Proposed...more

McDermott Will & Emery

Proposed HSR Rule Changes Likely to Increase Filings and Information Requirements for Private Equity Firms

McDermott Will & Emery on

What Happened: - The FTC and DOJ proposed new Hart–Scott–Rodino (HSR) rules that, if issued in final form, will significantly change HSR practice for Private Equity (PE) companies. - The Proposed Rules are subject to...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

Vedder Price

Tax Reform: Impact on Private Equity and M&A

Vedder Price on

On December 22, 2017, new tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Act”) was signed into law. The Act represents a major overhaul of the U.S. federal tax system and includes many new provisions,...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

Goodwin

Treasury Targets Tax Deferral in Leveraged Partnership Structures with New Regulations

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The Treasury issued new final, temporary and proposed regulations that take aim at, and significantly reduce the effectiveness of, leveraged partnership structures intended to achieve tax deferral to the contributing partner....more

Morrison & Foerster LLP

Practice Pointers on the Up-C Structure

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In a structure commonly referred to as an “up-C,” an existing limited liability company or other partnership form (referred to here for convenience as “LLC”) undertakes a public offering through a newly formed corporation,...more

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