Andrew Morris

In this edition of the Chambers Expert Focus Weil Tax Insight Series, Weil Tax partners Robert Frastai and Andrew Morris discuss the impact of the SEC’s recently adopted rules under the Investment Advisers Act of 1940 on certain tax structuring and compliance matters for private funds, including after-tax clawback obligations, blocker and withholding taxes that are allocated to

The post Chambers Expert Focus Weil Tax Insight Series: Tax Implications of New Rules Under the Advisers Act appeared first on Weil Tax BLOG.

Background In 2017, tax legislation was enacted to provide that (x) gain or loss derived by a non-US person on the sale or exchange of an interest in a partnership engaged in a U.S. trade or business is treated as effectively connected gain or loss and subject to U.S. tax (“ECI”) and (y) a transferee

The post <strong><u>New Partnership Withholding Obligations Effective as of January 1, 2023</u></strong> appeared first on Weil Tax BLOG.

Shortly before the new year, the Internal Revenue Service (“IRS”) dropped a holiday bombshell on the tax community when it issued a proposed regulation under the Foreign Investment in Real Property Tax Act of 1980 (“FIRPTA”). The proposed regulation would, if enacted in its current form, reverse a longstanding IRS ruling interpreting FIRPTA (the “2009

The post <strong>New IRS proposed regulation would reverse longstanding IRS ruling and upend commonly used real estate fund structures</strong> appeared first on Weil Tax BLOG.