Tax Alert
IRS issues final regulations for sales of partnership interests
Final section 864(c)(8) regulations clarify rules for foreign partners with ECI from transfers of partnership interests.
© 2021 RSM US LLP. All rights reserved.
Ideas & Insights
Tax Alert
COVID-19 delays FATCA and CRS reporting deadlines in key jurisdictions
The U.S., Cayman, and other jurisdictions extend deadlines for filing FATCA and CRS reports, but exams and compliance programs continue.
White Paper
Distressed company mergers and acquisitions—tax considerations
The economic impact of COVID-19 is immense. Distressed companies in need of capital may drive future M&A deals.
Insight Article
U.S. partners to determine their own GILTI inclusion
Final regulations issued in late June 2019 on GILTI inclusion could have a considerably differently impact on PE and VC fund structures.
Insight Article
Germany imposes requirements for PE and VC funds with German investors
If a fund is organized as a partnership, and has German investors, the annual filing of a partnership return in Germany is required.
Insight Article
Structuring deals in the era of TCJA and BEPS
Legislation relating to the Base Erosion and Profit Shifting (BEPS) Action Items has resulted in expanded tax due diligence engagements.
White Paper
Reporting considerations: U.S. PE funds with foreign investors
Understand the complexities associated with global reporting and withholding requirements for US private equity funds with foreign investors