Recent US tax law development related to fund managers for private equity / venture capital

October 2020

Recently Treasury and the IRS released several regulations that could have significant U.S. tax impact to USD funds that have U.S. person fund managers and investors. The new provisions require taxpayers to carefully review the current fund structure and various arrangements in place in order to meet the filing obligations. Furthermore, the new provisions contain traps for the unwary that could result in unfavourable tax consequences for the U.S. owners and managers of the funds. In this video publication, we will provide you with the updates for the relevant tax provisions and introduce several planning ideas that could mitigate the U.S. tax impact. 

Our publication will cover the relevant tax provisions and their application to USD funds:

• Section 1061 proposed regulations issued on 6 August 2020
• Section 951A regulations issued on 20 July 2020
• Section 163(j) regulations finalized on 28 July 2020
• Brief introduction to Biden tax reform proposal