Tax Talks

The Proskauer Tax Blog

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Jamiel E. Poindexter

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Jamiel E. Poindexter is a partner in the Tax Department and a member of the Private Funds Group. He focuses on tax and economic issues associated with the formation of and investments in U.S. and non-U.S. venture capital funds, buyout funds, funds-of-funds, secondary funds, and other investment partnerships.

Jamiel advises U.S. and non-U.S. sponsors and institutional investors on all types of fund-related transactions and operations, including:

  • structuring and raising private investment funds;
  • investments by institutional investors in private investment funds;
  • buy-side secondary transactions and sell-side secondary transactions;
  • restructuring of existing funds;
  •  spin outs;
  • succession planning; and
  • portfolio company investments.

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Section 1446(f) Proposed Regulations: Key Guidance on Partnership Interest Transfers by Non-U.S. Persons

By Jeanette Stecker, Xiaoyang Ma, Stephen Severo, Stuart Rosow, Scott S. Jones, Matthew Pincus, Mary B. Kuusisto, Martin T. Hamilton, Jamiel E. Poindexter, Jeremy Naylor, Jean Bertrand, David S. Miller, Amanda H. Nussbaum and Arnold P. May on Posted in International Taxation, IRS, Partnership Taxation, Tax Cuts and Jobs Act, Tax Reform, Withholding and FATCA
On May 13, 2019, the U.S. Internal Revenue Service (“IRS”) and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code[1] on dispositions of certain partnership interests by non-U.S. persons (the “Proposed Regulations”). The Proposed Regulations expand and in important ways modify earlier Notice 2018-29[2] on dispositions … Continue Reading

The Second Set of Proposed Opportunity Zone Regulations

By Jean Bertrand, Sean Webb, Stuart Rosow, Sejin Park, Scott S. Jones, Mary B. Kuusisto, Malcolm Hochenberg, Martin T. Hamilton, Jamiel E. Poindexter, Jeremy Naylor, Ira G. Bogner, David S. Miller, Alan Parnes, Amanda H. Nussbaum, Arnold P. May and Richard M. Corn on Posted in IRS, Opportunity Zones, Tax Cuts and Jobs Act, Tax Reform
Introduction On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section 1400Z-2 of the Internal Revenue Code (the “Code”) regarding the qualified opportunity zone program, which was enacted as part of the law commonly … Continue Reading

Proposed FDII Regulations under Section 250

By Elizabeth Johnston Wytock, Sean Webb, Stuart Rosow, Scott S. Jones, Mary B. Kuusisto, Malcolm Hochenberg, Michael Fernhoff, Martin T. Hamilton, Jamiel E. Poindexter, Jeremy Naylor, David S. Miller, Alan Parnes, Amanda H. Nussbaum, Arnold P. May and Richard M. Corn on Posted in GILTI, International Taxation, IRS, Tax Cuts and Jobs Act, Tax Reform
I.                   Introduction. On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible income” (“FDII”) under section 250 of the Internal Revenue Code.[1] Section 250 was enacted in 2017 as part of the tax reform act.[2] … Continue Reading

“Passthrough Deduction” Regulations Finalized

By David S. Miller, Jo Habenicht, Stuart Rosow, Scott S. Jones, Mary B. Kuusisto, Malcolm Hochenberg, Mitchell Gaswirth, Michael Fernhoff, Martin T. Hamilton, Jamiel E. Poindexter, Jeremy Naylor, Alan Parnes, Amanda H. Nussbaum, Arnold P. May and Richard M. Corn on Posted in IRS, Partnership Taxation, RIC (BDCs), Tax Cuts and Jobs Act, Tax Reform, U.S. Legislation
On January 18, 2019, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (the “Final Regulations”) regarding the “passthrough deduction” for qualified trade or business income under section 199A of the Internal Revenue Code.[1] The Final Regulations modify proposed regulations (the “Proposed Regulations”) that were released in August … Continue Reading

Summary of the Opportunity Zone Program

By Amanda H. Nussbaum, David S. Miller, Jean Bertrand, Jamiel E. Poindexter, Martin T. Hamilton, Mitchell Gaswirth, Malcolm Hochenberg and Sejin Park on Posted in IRS, Tax Cuts and Jobs Act
The Tax Cuts and Jobs Act enacted section 1400Z-2 of the Internal Revenue Code, which created the qualified opportunity zone program. The program is designed to encourage investment in distressed communities designated as “qualified opportunity zones” by providing tax incentives to invest in “qualified opportunity funds” (“opportunity funds”) that, in turn, invest directly or indirectly … Continue Reading
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