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IRS Issues Guidance on Transfers by Non-US Partners of Interests in Partnerships With US Assets

USA - January 10 2019 Proposed regulations under Section 864(c)(8) provide guidance for determining a foreign partnerâs effectively connected gains or...

Gaston Soler, Julie M. Marion.


Withholding Guidance Issued on Sale of Interests in a Partnership with US Assets

USA - April 5 2018 The guidance shows Treasury Regulations will ease administrative challenges and exclude certain transfers from the new withholding regime. Taxpayers...

Sean M. FitzGerald, Gregory T. Hannibal, B. Alan Van Dyke.


Private Equity Fund Managers: Annual Compliance Reminders and New Developments

USA - March 26 2018 US federal laws and regulations, as well as the rules of self-regulatory organizations (SROs), impose numerous yearly reporting and compliance...

John J. Sikora Jr., J. Ashley Weeks, Amy R. Rigdon, Sean M. FitzGerald, Chasmin D. Brooks, Barton B. Clark, Nabil Sabki, Yvette D. Valdez.


US Tax Reform: Key Business Impacts, Illustrated With Charts and Transactional Diagrams

USA - January 10 2018 On December 22, 2017, President Trump signed into law H.R. 1, informally known as the Tax Cuts and JOBS Act (the Act). The Act, the most comprehensive...

Bryant P. Lee, James H. Cole, Nicholas J. DeNovio, Joseph M. Kronsnoble, C. Timothy Fenn, B. Alan Van Dyke, Jiyeon Lee-Lim, Michael J. Brody, Julie M. Marion.


How US Tax Reform Proposals Will Affect Private Investment Funds and Asset Managers

USA, OECD - November 15 2017 Both the House and the Senate have recently released detailed tax reform proposals. This Client Alert addresses certain aspects of the proposals...

Gregory T. Hannibal, B. Alan Van Dyke.