Alternative Investments Tax Matters
Timely and relevant Tax and Audit legislative and regulatory alerts impacting the Alternative Investments industry
Partnership
- Evaluation of Trader vs. Investor
- Section 305(c)
- Insights into Schedule K-1 Reporting, Choosing a Method for Tax Basis Capital Reporting
- New Final and Proposed Regulations Under Section 163(j) – August 2020
- Updated Reporting requirements Form 1065 and Form 8865 – April 2020
- Summary of DE Partner Reporting Requirements – Schedule K-1 (Form 1065) – February 2020
- Sunrise Series: Preparing for year-end tax planning
- Sunrise Series: Major tax issues impacting private equity funds
- Release of draft 2019 Form 1065 and its Schedule K-1
- IRS Issues Proposed Regulations on Disguided Payments for Services
- Active Limited Partners in the Investment Fund Industry and Self-Employment Taxes
- Proposed Regulations – Qualifying Income, Minerals or Natural Resources-related Activities of Partnerships
Financial Products
- LIBOR transition for asset managers
- Changes to U.S. Income Tax Withholding on Convertible Bonds (IRC § and 305(c))
- IRS Clarifies Transactions that are Basket Options (Listed Transactions) and Basket Contracts (Transactions of Interest) and Extends the Date by which Disclosure is Required
- IRS Notices Impose Disclosure Obligations on Persons That Participate in Either a Basket Option or a Basket Contract
- Interaction between Sec. 475(F) and Sec. 1256
State and Local
- California Reportedly Plans to Withdraw Examples Regarding Look-through Sourcing for Asset Managers
- NYS Passthrough Entity Tax
- KPMG report: States proposing new taxes on financial transactions, wealth and investment income (assets.kpmg)
- Illinois: Budget agreement includes corporate tax revenue raisers (assets.kpmg)
- KPMG report: State, local tax changes (second quarter 2021, table format) (assets.kpmg)
Legislative Updates
- 2021 Tax Legislative Update - Biden
- 2021 Green Book Proposals
- Comparing Biden and Wyden international tax proposals
- KPMG Analysis and observations of tax proposals in Biden Administration’s FY 2022 budget
Foreign Taxes
- Tax reform affects nonresidents trading Argentine securities
- Sixth Circuit Reverses Tax Court on Mark to Market/Foreign Currency Option Can be a Foreign Currency Contract
- New Australian IMR Legislation Offers Capital Gains Tax Exemptions to Foreign Investment Funds
- Update Regarding FBAR Filing Requirements for Foreign Securities Accounts
- New limitation on interest paid on related hybrid transactions
Other
International
Asset Management Accounting Matters
SALT
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Jay Freedman
Principal, Tax Asset Management, KPMG US