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Does the Foreign-Derived Intangible Income Provision Benefit U.S. Fund Managers?

USA - April 11 2018 On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the “Act”). In previous alerts, we have discussed how the Act made significant...

Elizabeth C. Crouse, Charles H. Purcell, Rachel D. Trickett, Adam J. Tejeda.

Tax Issues for Private Equity

USA - March 12 2018 In regard to taxation and private equity funds, 2017 was defined by the Tax Cuts and Jobs Act (the "Act") which was signed on December 22, 2017. While...

Adam J. Tejeda.

Tax Reform and Investment Management: Certain International Provisions

USA - January 8 2018 In addition to the very significant changes to the domestic provisions of the Internal Revenue Code (the "Code"), the Tax Cut and Jobs Act (the "Act")...

Elizabeth C. Crouse, Charles H. Purcell, Won-Han Cheng, Adam J. Tejeda, Robert D. Starin.

Sale of U.S. Operating Partnerships by Non-U.S. Persons May Not Generate ECIU.S. Tax Court Declines to Follow Revenue Ruling 91-32

USA - August 4 2017 In a recently published decision, the U.S. Tax Court declined to follow the longstanding position of the U.S. Internal Revenue Service (“IRS”)...

Adam J. Tejeda.