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IRS Issues Proposed Regulations Intended to Clarify Carried Interest Rules

USA - August 24 2020 The Internal Revenue Service (IRS) recently issued proposed regulations under section 1061, a provision enacted as part of the Tax Cuts and JOBS Act…

Kevin Hall, Patrick J. McCurry, Alejandro Ruiz, Gregory M. Weigand

IRS Publishes Proposed Section 199A Regulations

USA - August 24 2018 The IRS recently issued proposed regulations under Section 199A, a provision enacted as part of tax reform to allow individuals and certain other…

Kevin Hall, Patrick J. McCurry, Alejandro Ruiz

Proposed regulations require significant entrepreneurial risk for a service partner's income to be a distributive share

USA - August 18 2015 On July 22, 2015, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released proposed regulations under Section 707(a)(2)(A)…

Kevin J. Feeley, Patrick J. McCurry

Tax considerations when acquiring non-U.S. portfolio companies—mitigating subpart F inclusions

USA - July 17 2014 It is important for private equity purchasers to mitigate the creation of Subpart F income in structuring the acquisition and holding of the stock of…

Jeffrey C. Wagner, Daniel N. Zucker

Venture funds: don’t fear the LLC

USA - April 15 2013 It has long been the case that venture funds (classified as partnerships for tax purposes) have insisted that limited liability companies (LLCs)…