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Investment Company Tax

Investment Company Tax Insights

January 24, 2024 Cynthia Pedersen, Robert Venables

IRS Recommits to Scrutiny of Limited Partners Providing Services to Private Funds

On January 12, 2024, the U.S. Department of the Treasury released a new fact sheet that in part reiterates, and revamps, the IRS’ commitment to their initiative of auditing limited partnerships. The release comes after five years of scrutiny in this area and an important court case...

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November 29, 2023 Lori Novak, Lisa Downing, Ryan McKenna

Regulatory Change and Retail Alternatives Center Stage at ICI Conference

At the Investment Company Institute (ICI) 2023 Tax and Accounting Conference held recently in San Antonio, regulatory readiness, the swift pace of the regulatory agenda and exploring investment alternatives were key focal points of the event. Panel after panel touched on regulatory change and...

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November 14, 2023 Brett Eichenberger, Erin McClafferty

Regulation, Scrutiny and — Positivity — at the 2023 Cohen Client Conference

We were proud to host this year’s Cohen Client Conference in our headquarter city of Cleveland, Ohio, welcoming back our clients and friends in the registered and private funds space. But most importantly it was great to gather and welcome the exchange of ideas and information, showing how...

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October 25, 2023 Andreana Shengelya

What is a 1940 Act Registered Private Real Estate Fund?

Asset managers have shown increasing interest in retail funds with private real estate portfolios over the last few years. Many of these funds are registered with the SEC under the Investment Company Act of 1940 as interval or tender offer funds. Placing certain asset classes, like real estate or...

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January 25, 2023 Jay Laurila

The Comingling of Digital Assets and Registered Funds: Can It Be Successful?

As the digital asset and registered fund spaces continue to intersect — with the first Bitcoin (BTC) regulated fund launching just over a year ago — there is much to sort through and many ongoing lessons to learn as to which products make sense for which types of investors. From...

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October 25, 2022 Brett Eichenberger

Regulation, Product Innovation, Crypto and More at This Year’s Cohen Client Conference

After two years of virtual Cohen Client Conference experiences, we were able to reunite in person this year in Nashville, Tennessee, allowing us to learn and connect in an interactive environment that can’t truly be replicated virtually. The group represented registered funds, investment...

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July 21, 2022 Andreana Shengelya

The Impact of Final Foreign Tax Credit Regulations on Mutual Funds

On January 4, 2022, the Treasury published final regulations on foreign tax credits (T.D. 9959). These regulations, among other things, change the rules for determining creditability of a foreign tax under Section 901 and 903 by requiring that foreign tax now meet certain attribution rules to be...

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February 21, 2022 Robert Venables

Does Your Partnership or S Corp Need to File a K-2 or K-3 for Its 2021 Taxes?

Partnerships and S Corporations with certain foreign activity or foreign owners may have a surprise in their returns this year — in the form of additional reporting via Schedules K-2 (Partners’ Distribute Share Items – International) and K-3 (Partner’s Share of Income...

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November 08, 2021 Cynthia Pedersen, Robert Venables

How Will the Infrastructure Investment and Jobs Act Impact Taxpayers?

** Updated 11/15/21 **On November 5, 2021, Congress passed the long-awaited Infrastructure Investment and Jobs Act, which was signed by President Biden on November 15. Below is a look at the two tax-related provisions included in the Act and their potential impact.1. Crypto Asset Information...

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October 25, 2021 Chris Bellamy

Regulation, Reinvention and Relationships Topped 2021 Cohen Client Conference

We were honored again to host our annual Cohen Client Conference this past week. While the event was virtual, we had several hundred attendees join us online over two days, representing mutual funds, investment advisers, hedge funds, ETFs, digital asset funds and more. This year more than ever...

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