Tax Talks

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Matthew Pincus

Matthew Pincus is a partner in the Tax Department and a member of the Private Funds Group.

With a focus on the private equity industry, Matt advises institutional and independent sponsors of buyout, debt, secondaries, emerging markets, and infrastructure funds on a broad range of U.S. tax matters. He guides clients on the U.S. tax aspects of fund formation, on-going operational matters, and carried interest arrangements.

Matt has significant experience advising U.S. and non-U.S. investors in connection with the tax and economic aspects of their investments in private funds. In addition, Matt regularly represents sponsors and investors in relation to fund secondary transactions, including tender offers, end-of-life fund recapitalizations and other sponsor-led liquidity solutions.

After law school, Matt served as a law clerk to the Hon. Gerard E. Lynch of the U.S. Court of Appeals for the Second Circuit.

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

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

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