Searching Content indexed under Tax by Patrick B. Fenn ordered by Published Date Descending.
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BBA Tax Audits: Final Deadline For Designating A U.S. Partnership Representative
Many fund managers have designated a management company, or a U.S. based affiliate or employee thereof, as the partnership representative or designated individual.
United States
28 Aug 2019
Opportunity Zones: New Guidance Sheds Light On How Private Equity Industry Can Take Advantage
Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) ...
United States
26 Oct 2018
U.S. Withholding Tax And Reporting Action Items For Investment Funds And Asset Managers (Fall 2018)
Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB)...
United States
9 Oct 2018
Carried Interest And Other Tax Reform Highlights For Investment Funds And Asset Managers
On November 2, 2017, the House of Representatives released the first draft of the Tax Cuts and Jobs Act, which could result in the most significant overhaul of the U.S. federal tax system since 1986.
United States
13 Nov 2017
U.S. Withholding On Synthetic Trades Over U.S. Equities—Further Delay Of Full Implementation Until 2019 (Notice 2017-42)
•The broader application of Section 871(m) has been delayed further until January 1, 2019, and, as a result, investment funds with non-U.S. feeders or investors up the chain should generally expect...
United States
23 Aug 2017
Renewal Of U.S. FATCA Registration For Certain Investment Funds By Monday, July 31, 2017
Recent IRS guidance requires that non-U.S. investment funds currently relying on an FFI agreement for their FATCA compliance must renew such agreement on the IRS website by July 31, 2017...
United States
21 Jul 2017
Final Regulations On MLP Qualifying Income Provide Clarification
Final regulations issued by the Treasury and the IRS on January 19, 2017, revealed a set of new rules interpreting "qualifying income" under Section 7704(d) of the Internal Revenue Code, affecting activities conducted by natural resources publicly traded partnerships.
United States
6 Feb 2017
FATCA: Final Deadline To Obtain A GIIN For Sponsored Investment Funds
Transitional relief for non-U.S. investment funds that have been previously permitted to provide only a sponsor's GIIN to avoid incurring FATCA withholding ends on December 31, 2016.
United States
16 Dec 2016
New Partnership Liability And Disguised Sale Regulations
These proposed regulations generally do not apply until on or after the date that such regulations are published as final regulations.
United States
13 Oct 2016
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