Tax Talks

The Proskauer Tax Blog

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Dan Paulos

Dan is a partner in the Tax Department and focuses his practice on advising asset managers and investors on tax matters. Specifically, Dan advises asset managers on U.S. and international tax implications of fund formation and fund investments. Dan’s clients include credit funds, private equity funds, hedge funds, real-estate funds and infrastructure funds. These clients benefit from Dan’s broad experience and background and Dan’s ability to advise throughout the fund lifecycle, from formation to wind-down.

Dan has extensive experience advising credit funds on structuring inbound U.S. investments and planning for onshore U.S. activities, including loan origination activities. Dan also advises clients (typically on the creditor-side) with respect to workout and bankruptcy matters, and other aspects of distressed investing. Dan regularly advises private equity and infrastructure funds with respect to their investment activities and has advised sponsors with respect to complex cross-border IPOs, structured in careful consideration of inversion and other US tax considerations.

Prior to joining Proskauer Dan was a principal at KPMG.

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New Bill Would Deny Section 892 Benefits To Certain Sovereign Wealth Funds

On July 26, 2023, Senate Finance Chairman Ron Wyden (D-OR) introduced the Ending Tax Breaks for Massive Sovereign Wealth Funds Act (the “bill”), which would deny the benefits of section 892 of the Internal Revenue Code[1] to sovereign wealth funds whose foreign government holds more than $100 billion of investable assets,[2] and either (i) is … Continue Reading

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally would treat domestic partnerships as aggregates of their partners (rather than as entities) for purposes of determining income inclusions under the Subpart F provisions applicable … Continue Reading

Senator Manchin Announces That He Will Not Support the Build Back Better Act – Where Things Stand Now

Today, December 19, 2021, Senator Joe Manchin (D., W.Va.) said that he opposes the Build Back Better Act, which effectively prevents its passage.  While there are no immediate prospects for the Build Back Better Act to become law, future tax acts tend to draw upon earlier proposals.  With a view to future tax proposals, this … Continue Reading

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