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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
On August 29, 2023, the IRS published detailed proposed regulations addressing digital asset broker reporting requirements (the “Proposed Regulations”). The Proposed Regulations elaborate on the 2021 changes to the Internal...more
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
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
The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more