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…
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 added to…
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…
With the release of Notice 2020-18, the IRS has now expanded the limited relief it previously granted three days ago in Notice 2020-17 with respect to Federal income tax payments (including…
These rush overnight bullets describe the Senate Republican proposal for Phase 3 of the government’s stimulus response to the coronavirus (COVID-19) emergency. The rush summary describes…
President Trump has signed two significant executive orders regarding transparency in federal agency guidance and enforcement. This visual memorandum provides an overview of and key…
On September 9, 2019, the Internal Revenue Service released proposed regulations that, if finalized in their current form, would in many cases dramatically reduce the portion of a company’s…
The Treasury Department and IRS in April released a second set of proposed regulations governing tax incentives for investment in “qualified opportunity zones.” We expect the new rules to…
