On Tuesday, December 27, 2022, the IRS released a notice that describes proposed regulations that the IRS intends to issue addressing the application of the new corporate alternative mini...
On Tuesday, December 27, the IRS released a notice that describes proposed regulations that the IRS intends to issue addressing the application of the 1% stock repurchase excise tax that ...
On August 7, 2022, the United States Senate approved the Inflation Reduction Act of 2022 (H.R. 5376), an energy and healthcare bill that includes new tax provisions, including a new corpo...
On July 27, Sens. Schumer and Manchin announced an agreement on the Inflation Reduction Act of 2022. Key tax provisions include (1) imposing a 15% corporate AMT on the adjusted book inco...
This client update identifies the principal issues that private equity firms and their portfolio companies should consider and address with the help of counsel before any purchase of port...
Davis Polk partners David Schnabel and Patrick Sigmon and counsel Ethan Goldman recently authored “Key Considerations and Relevant Ambiguities for Fund Managers Under the Final Carried ...
The IRS has issued final regulations on the taxation of carried interest under Section 1061 of the tax code, which was added in the 2017 tax law and provides that capital gain allocated u...
Last Friday, the IRS and Treasury proposed regulations (the “Carried Interest Regulations”) on the taxation of carried interest under Section 1061 of the tax code. Section 1061 was ad...
Davis Polk has prepared two memos describing key portions of the bill just signed into law: the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). In this memo, we cover tax ...
The coronavirus (COVID-19) emergency has led to the debt of many companies in private equity portfolios trading at a significant discount. As a result, an increasing number of private equ...
