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Unrelated Business Taxable Income (UBTI) issues for Private Equity and Venture Capital Funds

Private Equity (PE) and Venture Capital (VC) funds often attract significant investment from US tax-exempt entities.  In doing so, these funds may need to avoid having Unrelated Business Taxable Income (UBTI).  This article will address some of the scenarios that can cause a fund to generate UBTI. US tax-exempt entities such as qualified pension funds, […]

IRS Issues Guidance and Solicits Feedback on Nonfungible Tokens (“NFTs”)

On March 21, 2023, the Treasury Department and the Internal Revenue Service (the “IRS”) announced that they were requesting comments regarding upcoming guidance on US tax treatment of certain nonfungible tokens (“NFTs”) as collectibles under Internal Revenue Code (IRC) section 408(m). NFTs An NFT is a unique digital identifier that is used to certify ownership and […]

UK Spring Budget 2023

Written by Johana Regatuso and Harry Swift.  Chancellor Jeremy Hunt has now delivered his statement on UK tax and spending. Out of the past five Chancellors, he is only the second to hold the iconic red box outside No. 11 Downing Street. There has been very little in the press in the run-up to this […]

Expanding your business to the US: What to know before you go

Even as venture capital markets expand around the world and forge new hubs for business, the unique allure of the US remains constant. The US boasts a vast and affluent base of consumers, robust supply chains and infrastructure, as well as a wide diversity of markets. At some point most businesses will think about US […]

US Owners of foreign personal pension plans

US taxpayers often participate in foreign pension plans as these can be useful, tax preferred, investment tools in the jurisdiction where they are tax resident.  Complexities arise with how these plans are reported to the IRS, especially considering the substantial US tax penalties associated with non-compliance. What is a Foreign Private Pension Plan? Pension plans […]

Passive Foreign Investment Company (PFIC)

American citizens and resident aliens are all too familiar with the IRS practice of worldwide taxation. For most expats, this simply means having to file an additional tax return each year. But where the rules can get complex and, in many cases counter-intuitive, is where these rules extend their reach into overseas assets owned by […]

USTAXFS new appointments

USTAXFS UK appoints ex-EY Frank Hirth’s, Glenn Snow, as Tax Director in its Private Client Group, alongside a series of strategic hires and promotions We are delighted to announce that USTAXFS UK has appointed award-winning industry star Glenn Snow, formerly EY Frank Hirth, to the position of Tax Director within the Private Client Group. The […]

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