Weil Tax BLOG - Feed

QAHCs and Credit Funds – Update on Regulatory Registration Requirements

Aron Joy — Mon, 25 Sep 2023 14:25:12 +0000

In April 2022, the UK introduced the Qualifying Asset Holding Company (“QAHC”) regime. The regime is intended to entice investment funds, and certain other investors, to establish their holding structures in the UK as opposed to, for example, Luxembourg or Ireland. To this end, a range of tax reliefs are available to companies that qualify for and elect into the regime, such as no withholding tax on interest paid by a QAHC, the ability to use profit participating instruments to offset returns on debt investments and a blanket UK corporation tax exemption for gains on the sale of (most) shares. QAHCs can also be useful, in particular, for funds whose managers are based in the UK who may have difficulty in establishing or demonstrating sufficient substance in an overseas holding company, which may result in issues with local substance requirements in underlying investment jurisdictions or the proposed Anti-Tax Avoidance Directive III, if it is enacted.

Certain Carried Interest Tax Changes in the Schumer – Manchin Tax Reconciliation Bill (Inflation Reduction Act of 2022)

Robert Frastai — Thu, 28 Jul 2022 19:45:20 +0000

On July 27, 2022, Senate Majority Leader Chuck Schumer and Senator Joe Manchin reached a deal on new legislation entitled the “Inflation Reduction Act of 2022” to be added to the fiscal year 2022 budget reconciliation bill. President Biden issued a statement of support shortly after its announcement. The significant tax changes to the treatment

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Potential Tax Impact of Proposed SEC Regulations

Robert Frastai — Fri, 11 Mar 2022 06:45:00 +0000

On February 9, 2022, the Securities and Exchange Commission (SEC) proposed new rules that, if implemented, would have profound effects on the private equity industry and the relationship among the SEC, fund advisers and investors (the SEC Proposal).1 The proposed rules would prohibit private fund advisers from engaging in certain activities, regardless as to whether

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New Tax Regime for UK Asset-Holding Companies: Welcome Reform Efforts

Aron Joy — Wed, 28 Jul 2021 10:52:46 +0000

The UK government has moved a step closer to introducing a new and advantaged tax regime for UK asset-holding companies (“AHCs”) for investment funds. On July 20, 2021 it published a policy paper and draft legislation providing for the implementation of certain features of this proposed new regime. The proposals are part of a drive

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Final 1061 Regulations

Robert Frastai — Mon, 11 Jan 2021 23:59:12 +0000

On January 7, 2021, the IRS and Treasury Department issued final regulations (T.D. 9945) under Section 1061 of the Internal Revenue Code of 1986, as amended (the “Code”, and such regulations, the “Final Regulations”) detailing, among other things, how long-term capital gain may be recharacterized as short-term capital gain in respect of carried interest arrangements

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Carried Interest Proposed Regulations

Robert Frastai — Wed, 05 Aug 2020 20:08:51 +0000

On July 31, 2020, the IRS issued proposed regulations ([REG-107213-18]) under Section 1061 of the Internal Revenue Code (the “Code”, and such proposed regulations, the “Proposed Regulations”) applicable to, among other things, common carried interest arrangements of private equity funds (“Funds,” or where stated in the singular form, a “Fund”). The Proposed Regulations are generally

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Cayman Islands Added to the EU Blacklist — Private Fund Sponsor Update

Robert Frastai — Wed, 08 Apr 2020 15:15:27 +0000

Update alert: Proposed domestic tax penalties emerge in Luxembourg in enforcement of EU blacklist We recently reported on the addition of the Cayman Islands to the EU list of non-cooperative jurisdictions for tax purposes (the “EU blacklist”) on February 18, 2020 and key consequences for private fund sponsors. On March 30, 2020 the Luxembourg government

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Weil Advised Brookfield Asset Management in its Formation of $20B Brookfield Infrastructure Fund IV

Weil Tax Blog — Fri, 07 Feb 2020 14:48:39 +0000

Weil advised Brookfield Asset Management, Inc. in the formation of its latest flagship global infrastructure fund, Brookfield Infrastructure Fund IV, with total commitments of $20 billion. Weil previously advised Brookfield in its formation of Brookfield Infrastructure Fund III, a $14 billion fund, as well as its predecessor funds. The Weil team was led by Private Funds

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