Thomas P. Ward
McDermott Will & Emery
Articles
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…
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)…
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…
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)…
