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Insights and Analysis

The secondaries market adjusts to further changes in the US ECI withholding regime

Beginning 1 January 2023, the US tax rules impose a “secondary” or “backstop” withholding obligation on both US and non-US partnerships. Under the new provisions,...

News

U.S. tax alert: Inflation Reduction Act, CHIPS Act & Private Capital

On August 16th, President Biden signed the Inflation Reduction Act of 2022 (H.R. 5376) into law (the “IRA”). Among the most significant provisions in the bill are extensions and ...

Insights and Analysis

Final regulations – U.S. withholding tax on transfers of partnership interests

Since 2018, the buyers, sellers, and partnerships engaging in secondary and other transactions involving partnership interest transfers have been navigating complicated U.S. tax and related ...

Publications

Final regulations – U.S. withholding tax on transfers of partnership interests

Since 2018, the buyers, sellers, and partnerships engaging in secondary and other transactions involving partnership interest transfers have been navigating complicated U.S. tax and related ...

Insights and Analysis

Final regulations - Foreign partner’s U.S. tax liability on transfer of partnership interest

Given the overall development of the secondaries market and the increasing volume and size of secondary funds, the U.S. tax and withholding regime that applies to a foreign partner...

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