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Investment Management Tax Alerts Library

Investment Management Tax Alerts are issued periodically and highlight breaking tax developments impacting the investment management industry.

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IRS issues proposed regulations and revenue procedures 2014-45 on method of accounting for gains and losses and loss disallowances on shares in money market funds with a floating net asset value
July 31, 2014

IRS issues private letter Ruling 201418061
July 31, 2014

Senate investigates use of barrier option baskets
July 31, 2014

IRS issues Revenue Ruling 2014-18: Application of section 457A to certain equity arrangements
June 26, 2014

House subcommittee hears testimony on Mobile Workforce Act
June 2, 2014

The DFA case decision released, positively impacting U.S. and other non-EU resident funds pursuing EU withholding tax claims
April 11, 2014

Treasury issues Notice 2014-14 revising effective date for imposition of gross tax on certain equity linked instruments under section 871(m)
March 10, 2014

Treasury issues final and newly proposed regulations covering the net investment income tax
January 17, 2014

Treasury issues revised proposed regulations, as well as final regulations, governing the imposition of withholding tax on equity derivatives
December 16, 2013

Hedge fund partnership interest donation to a private foundation
October 4, 2013

Recent Tax Court decision holds that a writer of covered calls was not a trader 
September 25, 2013

Sun Capital Partners: First Circuit holds private equity fund potentially liable for portfolio company pension obligations due to trade or business activity
September 17, 2013

New York state appellate court declares metropolitan commuter transportation mobility tax constitutional
August 16, 2013

IRS proposes changes to RIC asset diversification testing regulation examples (Reg §1.851–5) related to controlled groups
August 8, 2013

Proposed de minimis exception to wash sale rules for certain money market fund redemptions
July 15, 2013

IRC § 1256 contracts and revenue ruling 2013-5
June 14, 2013

Update on the IRS form 8949
April 25, 2013

IRS Form 8949: Sales and other dispositions of capital assets
March 1, 2013

New publicly traded debt tax regulations
February 19, 2013

Recovering withholding on interest-related or short-term capital gain dividends paid to foreign shareholders of RICs
January 28, 2013

FATCA update
January 17, 2013

The American Taxpayer Relief Act of 2012: A focus on asset managers
January 10, 2013

IRS issues Revenue Ruling 2012-29 clarifying the effective date of capital loss carryforwards for excise tax purposes
October 9, 2012

New York state court declares MTA payroll tax unconstitutional
September 26, 2012

IRS amends rules to require withholding on dividend equivalents paid to foreigners
September 4, 2012

Final Regulations: Aircraft disallowance provisions
August 8, 2012

Draft India GAAR guidelines and examples
July 3, 2012

Australian investment manager regime
June 22, 2012

2012 India budget
June 21, 2012

Asset managers and ERISA fee disclosure
June 14, 2012

ECJ rules against France on withholding tax rules applied to nonresident funds
May 11, 2012

EU law based withholding tax claims
April 13, 2012

Form 8938
April 9, 2012

India 2012 budget holds unpleasant surprises for nonresidents
March 30, 2012

Electronic delivery of Schedules K-1
February 21, 2012

Treasury issues guidance on withholding on total return swaps
January 31, 2012

Proposed regulations providing guidance on the taxation of the income of sovereign wealth funds from investments in the U.S.
January 19, 2012

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