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Key Provisions of House Committee Build Back Better Proposal That Could Impact the Private Equity & Venture Capital Industry
Posted by Robert Kerr on Sep 22, 2021 11:23:48 AM

The House Ways and Means Committee issued their initial proposal to help fund the Build Back Better Act reconciliation bill on September 13. The proposal includes a number of tax increase provisions that if passed in current form would have a significant impact on investment funds in the Private Equity and Venture Capital industry, their investors, and portfolio companies.

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Topics: Private Equity & Venture Capital, PE/VC, GILTI, global intangible low-taxed income, Qualified Small Business Stock, QSBS, FDII, carried interest, Carried Interest Regulations, section 1061, House Ways and Means, long-term capital gain, Build Back Better, NIIT, foreign derived intangible income, net investment income tax

New GILTI Regulations Provide Relief for Taxpayers
Posted by Barret Pinto on Jul 23, 2019 12:16:00 PM

On June 14, the U.S. Department of Treasury (Treasury) and the IRS released final regulations for the tax on Global Intangible Low Taxed Income (GILTI), a provision that came from the tax reform law commonly known as the Tax Cuts and Jobs Act (TCJA). Concurrently, the Treasury and IRS released proposed regulations on Subpart F inclusions.

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Topics: Private Equity & Venture Capital, PE/VC, portfolio companies, GILTI, global intangible low-taxed income

'GILTI' Regulations: What it Could Mean for Private Equity and Venture Capital Firms
Posted by Barret Pinto on Oct 1, 2018 5:13:50 PM

On Sept. 13, 2018, the Treasury and IRS released proposed regulations related to the enactment of the tax on global intangible low-taxed income (“GILTI”). GILTI was included as part of the 2017 tax reform law introduced as the Tax Cuts and Jobs Act (TCJA). The proposed regulations address several areas, including computational, definitional and anti-avoidance rules for GILTI. The guidance includes provisions applicable to partnerships as well as consolidated groups, but leaves open many questions related to look-through treatment for foreign tax credits, and the interaction with other newly enacted code sections.

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Topics: Private Equity & Venture Capital, PE/VC, portfolio companies, GILTI, global intangible low-taxed income

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