Entries by Richard A. Cagnetta

Requirements for Qualified Opportunity Funds, Clarified by IRS

The qualified opportunity zone (QOZ) program was created as part of the 2017 tax reform package. It offers attractive tax benefits to investors who reinvest capital gains in eligible economically distressed communities. The vehicle for making these investments is known as qualified opportunity funds (QOFs). In the months following passage of the legislation, many investors […]

What New IRS Business Interest Expense Deduction Limitation Regs Mean for Your Investment Partnership

Recently, the IRS proposed regulations that provide new guidance on the limitation for business interest expense deductions. The limitation, found in Internal Revenue Code Section 163(j), was added by the Tax Cuts and Jobs Act (TCJA). Investment partnerships may find identifying and tracking business interest subject to the limit, as well as calculating the limitation […]

New Limit on Business Interest Deductions

The Tax Cuts and Jobs Act (TCJA) imposes a new limit on business interest deductions for taxable years beginning in 2018. This article will focus on the new law’s application to partnerships and address its applicability to various types of investment partnerships. The New Law Limit For tax years beginning after 2017, the TCJA amended […]

New Tax Withholding Rules for Dividend Equivalent Payments

On January 1, 2017, new regulations will take effect, significantly expanding tax withholding requirements for U.S. source dividend equivalent payments to non-U.S. persons. Payments covered by the new rules will be subject to the same 30% U.S. withholding tax (less under certain tax treaties) as U.S. source dividends. Funds whose portfolios include derivatives and other instruments […]