On April 23, 2020, the Treasury Department and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 512(a)(6) of the Internal Revenue Code (the “Code”). Section 512(a)(6) was enacted as part of the 2017 Tax Cut and Jobs Act (the “TCJA”) and requires exempt organizations (including individual retirement accounts)[1] to … Continue Reading
First Circuit reverses District Court’s decision that co-investing funds were in de facto partnership which controlled portfolio company and could be held liable for portfolio company’s withdrawal liability; decision may be significant for multiemployer pension funds and private investment funds. Read the full alert.… Continue Reading
UK General Tax Developments HMRC updates guidance on what constitutes “ordinary share capital” Following the decision by the First-tier Tribunal (FTT) in Warshaw V HMRC, reported in our UK tax blog earlier this month, HMRC has updated its guidance on what constitutes “ordinary share capital” for the purposes of most tax provisions using that term. As well as … Continue Reading
H.R. 1, commonly referred to as the Tax Cuts and Jobs Act, implements sweeping changes to the U.S. tax system. These changes will alter the fundamental tax principles upon which many investment and organizational decisions by the private investment industry were made. Lawyers in our Tax and Private Investment Funds groups hosted a 1-hour webinar … Continue Reading
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