Insights

This alert briefly discusses the Fifth Circuit’s August 12, 2026 opinion in K Alain, L.L.L.P. v. Commissioner (the “Recent Opinion”). In the Recent Opinion, the Fifth Circuit withdrew its prior decision and issued a new decision generally affirming the IRS’s position in the case. The prior decision, which was favorable to the taxpayer, was issued in January…

Client Alerts | August 19, 2026 | Hedge Funds | Private Equity Funds

This alert is a reminder of the approaching deadlines and action items regarding the New York State Pass-Through Entity Tax (the “NYS PTET”) and the New York City Pass-Through Entity Tax (the “NYC PTET”). Deadline: March 15, 2026 The deadline to elect into the NYS PTET and the NYC PTET for 2026 is March 15,…

Client Alerts | March 4, 2026 | Hedge Funds | Private Equity Funds

At the beginning of each year, we send a newsletter to our clients and friends regarding Section 475(f) mark-to-market elections as a reminder to consider whether to make or revoke such election. A 475(f) election must be made by calendar-year partnerships on or before March 16, 2026 (as March 15 falls on a Sunday), for…

Client Alerts | March 3, 2026 | Hedge Funds | Private Equity Funds

This newsletter briefly highlights certain tax issues and planning opportunities that fund managers and high-net-worth individuals should consider (or reconsider) before and shortly after the end of 2025. While the One Big Beautiful Bill Act (the “OBBBA”), signed into law earlier this year, included many changes to the tax system, the final bill had far…

Client Alerts | November 24, 2025 | Hedge Funds | High Net Worth Individual Planning | Private Equity Funds

The Bureau of Economic Analysis (BEA) Form BE-180, the 2024 Benchmark Survey of Financial Services Transactions Between U.S. Financial Services Providers and Foreign Persons, is due by July 31, 2025 (but extensions may be obtained), and may apply to many hedge fund managers/general partners. Form BE-180 is required every five years. The purpose of Form…

Client Alerts | July 24, 2025 | Hedge Funds | Private Equity Funds

On July 4th, President Trump signed into law a new tax act, representing the administration’s key tax policies. While initial proposals for this legislation indicated it might have far more impact on funds and fund managers, many of these proposals were ultimately not included. Insofar as its impact on funds and fund managers, what was…

Client Alerts | July 10, 2025 | Hedge Funds | Private Equity Funds

At the beginning of each year, we send a newsletter to our clients and friends regarding Section 475(f) mark-to-market elections as a reminder to consider whether to make or revoke such election. A 475(f) election must be made by calendar-year partnerships on or before March 15th of the year in which the election is to…

Client Alerts | February 21, 2025 | Hedge Funds | Private Equity Funds

This alert is a reminder of the approaching deadlines and action items regarding the New York State Pass-Through Entity Tax (the “NYS PTET”) and the New York City Pass-Through Entity Tax (the “NYC PTET”). Deadline: March 15, 2025 The deadline to elect into the NYS PTET and the NYC PTET for 2025 is March 15,…

Client Alerts | February 20, 2025 | Hedge Funds | Private Equity Funds

Fund managers may be required to file Treasury International Capital (“TIC”) Form SHL, Report of Foreign-Residents’ Holdings of U.S. Securities, Including Selected Money Market Instruments (SHL (2024)) by August 30, 2024, based on the fair value (determined as of June 28, 2024) of certain U.S. securities issued to foreign persons. This client alert focuses on…

Client Alerts | August 7, 2024 | Hedge Funds | Private Equity Funds