Section 892 Income Tax Exemption for Sovereign Wealth Funds
Leveraging New Regulations to Avoid Taxation for Commercial Activities
Recording of a 110-minute CLE/CPE webinar with Q&A
This teleconference will provide tax law advisors with a review of pending tax rule changes affecting sovereign wealth funds and other foreign-controlled entities seeking private U.S. investments that won't endanger federal income tax exemption. The panel will offer approaches to avoid exemption-spoiling classifications.
- Sovereign wealth funds and the IRC Sec. 892 tax exemption
- Commercial activity limitation
- "All or nothing" approach
- Problems created for sovereign wealth funds under the traditional approach
- Proposed rule changes
- No partnership attribution to limited partners
- Investing/trading in financial instruments
- Inadvertent commercial activity
- Disposition of interests in U.S. real property
- Annual determination of controlled commercial entity status
- Leveraging the proposed rule changes
The panel will review these and other key questions:
- What kinds of commercial activity have traditionally triggered disqualification for Sec. 892 tax exemption and what has changed?
- What is the status of the "all or nothing" rule following the proposed regulations?
- How can sovereign wealth funds and other entities leverage the revised approach to determine whether the tax exemption applies?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
John T. Lillis
White & Case
He works on a broad range of transactions regarding tax issues, including investment fund formation and joint ventures... | Read More
He works on a broad range of transactions regarding tax issues, including investment fund formation and joint ventures typically involving cross-border structuring to achieve tax efficiencies from a U.S. and non-U.S. tax perspective. He has worked with both U.S. and non-U.S. sponsors in establishing equity and other investment funds.Close
White & Case
He is assigned to the firm's Tax Department and Investment Funds Group. His client work addresses domestic and... | Read More
He is assigned to the firm's Tax Department and Investment Funds Group. His client work addresses domestic and international tax planning for corporate and partnership transactions, with a particular focus on private equity.Close
O'Melveny & Myers
His practice covers a broad range of federal income tax matters, with a focus on the tax aspects of capital markets... | Read More
His practice covers a broad range of federal income tax matters, with a focus on the tax aspects of capital markets and finance transactions, mergers and acquisitions, cross-border transactions, REITs and matters relating to private equity and hedge funds as well as to their investors.Close