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IRS Releases Proposed Section 892 Regulations; Private Equity Fund Investments By Foreign Government Partners Potentially Affected
2 November 2011
IRS Proposed Regulations released today liberalize the existing rules regarding the exemption from U.S. tax of investment income derived by foreign governments, especially the rules relating to investments in partnerships.
These changes will likely facilitate investment by foreign government entities (including sovereign wealth funds) in private equity funds and other managed investment vehicles.
Gary M. Friedman
Peter A. Furci
Matthew D. Saronson
David H. Schnabel
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Adjustments to the Basis of Partnership Assets (Sections 734, 743 and 754)