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...
In a decision
released July 13, the U.S. Tax Court held that gain realized by a non-U.S. investor on the disposition of an interest in a partnership that operated a U.S. business was gen...
On November 2, 2011, Treasury released proposed revisions to the regulations under Section 892 of the Internal Revenue Code of 1986 (the “Code”). Section 892 provides an exemption fro...
Today, the IRS released guidance that provides significant relief to persons considering the extent to which they need to submit a Report of Foreign Bank and Financial Accounts (an “FBA...
The Treasury Department has released proposed regulations that would provide some relief to filers attempting to determine their obligations under the rules regarding the Report of Foreig...
