Daniel Carmody

2 months ago | jdsupra.com | Andreas Andrews |Jennifer Breen |Daniel Carmody

In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms, and new regulations proposed by the IRS and the US Department of the Treasury (Treasury). Private equity funds, hedge funds, and other private investment funds, along with their investors and advisors, should be cognizant of these developments.

Feb 6, 2024 | jdsupra.com | Andreas Andrews |Jennifer Breen |Daniel Carmody

February 6, 2024 Andreas Andrews, Jennifer Breen, Daniel Carmody, Adam Holmes, Kendall Keshtkar, Richard LaFalce, Meghan McCarthy, Sarah-Jane Morin, Daniel Nelson, Jason Traue Morgan Lewis + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: 2023 saw a number of key tax developments that may affect the private fund industry going into 2024, from key US Tax Court opinions and updates to Internal Revenue Service (IRS) Forms, to new...

Dec 4, 2023 | morganlewis.com | Jennifer Breen |Richard Zarin |Daniel Carmody |Stephen C. Tirrell

Private equity, hedge fund, and other investment fund sponsors should be aware of the recent development in the Internal Revenue Service’s (IRS’s) audit campaign with respect to potential liability for Self-Employment Contributions Act (SECA) tax on investment professionals through their limited partnership interests in fund management vehicles.

Jun 14, 2023 | jdsupra.com | Barton Bassett |Daniel Carmody |Kendall J. Keshtkar

Creating a financial technology (fintech) firm comes with a host of tax considerations and implications. Decisions about the business’s structure, along with the location of both the business itself as well as its employees, can affect the entity’s tax obligations. FORMATIONCharacteristics of a fintech business and specific concerns of the business owner(s) will ultimately drive its structure.

May 26, 2023 | jdsupra.com | Daniel Carmody |Kendall J. Keshtkar |Scott Lee

A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a partnership profits interest in exchange for services can support non-taxable treatment at grant. WHAT IS A PROFITS INTEREST? Under IRS Revenue Procedure 93-27 [1] (Rev.