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…
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…
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 from U.S…
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 Foreign…
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 "FBAR")…
