Every indexed document

and readers should not act upon the information in this Alert

assuming that the foreign feeder is a passive

its net income would be calculated under the rules applicable to corporations

the fund's sponsor may find that US high net worth individuals may now

there is a lack of clear guidance from the Internal Revenue

then such expenses would be completely deductible as trade or business expenses. This

the Tax Act completely repeals the deductions previously allowed to individuals

derive a significant benefit from this deduction.

the benefit of the available deduction is phased out ratably as the

are not permitted to claim the ""qualified business income"" deduction unless the taxpayer's

the owner or pass through taxpayer's tax deduction would be a minor amount or zero.

it does not apply to reasonable compensation income and guaranteed payments

dividends (other than certain ordinary income dividends paid by REITs)

such deduction results in an effective federal income tax rate of 29.6% on such

qualifying income from publicly traded partnerships

which are also taxed at long-term capital gains

it appears that any unrealized capital gains which have already been allocated to

2018 and existing carried interests are not

which typically have a longer than three-year holding period

the Act applies a three-year holding period requirement for capital