Firm News | November 1, 2021
On November 2, 2015, new partnership audit rules were enacted as part of The Bipartisan Budget Act of 2015. The new audit rules could have a significant impact on partnerships generally and on investment partnerships in particular. The new rules were enacted because the IRS and Congress felt that the current audit rules, referred to…
Client Alerts | December 1, 2015 | Hedge Funds
This newsletter briefly highlights certain tax issues and planning that hedge fund managers should consider (or reconsider) before year-end. Tax rates are scheduled to remain the same in 2016. 1. Federal Income Tax Rates in 2015 and 2016. Long-term capital gains and qualified dividend income: 25%* Ordinary income: 44.6%* (*includes effect of net income investment tax and 3%…
Client Alerts | November 18, 2015 | Hedge Funds
The United States Bankruptcy Court for the Southern District of New York held last week that a foreign corporation that had issued debt pursuant to an indenture with a New York choice of law and New York forum selection clause and had commenced an insolvency proceeding in its home jurisdiction may file for chapter 15…
Client Alerts | November 5, 2015
The Bureau of Economic Analysis (BEA) Form BE-180, the 2014 Benchmark Survey of Financial Services Transactions Between U.S. Financial Services Providers and Foreign Persons, is due by November 1, 2015 (30 or 60 day extensions may be obtained), and may apply to many hedge fund managers. The purpose of Form BE-180 is for the BEA…
Client Alerts | October 20, 2015 | Hedge Funds
As part of the 2015 New York State corporate tax reform, significant changes were made to the definition of investment capital under Article 9-A (Corporate Tax) of the New York Tax Law. Income from investment capital (generally, stocks held for more than a year) is subject to preferential treatment in New York State and New…
Client Alerts | September 28, 2015 | Hedge Funds
On September 18, 2015, the IRS issued Notice 2015-66 announcing its intent to amend FATCA regulations to extend timelines for certain transition rules and to reduce certain compliance burdens on withholding agents by modifying the rules for grandfathered obligations. Most importantly, withholding on gross proceeds will not be required until January 1, 2019 (extended from…
Client Alerts | September 25, 2015 | Hedge Funds
We are pleased to announce that 16 of the firm’s attorneys were selected for inclusion in the 2015 edition of Super Lawyers®, a national legal ranking. Attorneys were nominated by their peers and recognized for their outstanding professional achievement in several legal practice areas including business/corporate, business litigation, estate & probate, mergers & acquisitions, real…
Firm News | September 23, 2015
On September 17, 2015, the IRS issued final regulations (the “Final Regulations”) requiring withholding on certain dividend equivalent payments beginning January 1, 2017. (Please see our prior newsletter regarding the delay of imposing withholding on dividend equivalents.) The Final Regulations reflect some important changes suggested in comments to the IRS following the issuance of the…
Client Alerts | September 22, 2015 | Hedge Funds
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Firm News | September 4, 2015
We have previously written to our clients about the importance of complying with the requirements of the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (the “HSR Act”) when building positions that may become activist in the future. [“Antitrust Filing Mistakes Can Cost Activists“]. On August 24, 2015 the United States Federal Trade Commission (the…
Client Alerts | August 26, 2015 | Mergers & Acquisitions | Investor Activism | Hedge Funds
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