United States | Proposed IRC Section 899 would affect certain asset management entities
|Tax Alerts, Information Reporting, Asset ...|United States
Proposed Section 899 would respond to "unfair foreign taxes" by imposing increased US tax rates on certain asset management entities, including hedge funds, private equity funds, regulated investment companies, business development corporations, real estate investment trusts, and sovereign wealth funds.
If enacted, proposed Section 899 would increase tax rates on US-source income received by applicable persons, leading to higher withholding rates for foreign investors.
Given the broad reach of pro…
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