All posts by Cooley

Q4 2017 Venture Financing Report and Commentary From Michael Ronen of SoftBank Investment Advisers

Michael Ronen from SoftBank Investment Advisers discusses his take on the state of venture capital investing. On market fluctuations: Investing is a cyclical business, but we continue to feel good about our outlook because we generally take a long-term view, backing seasoned management teams and differentiated technologies with significant capital […]

S Corporation “Dodge” Won’t Work to Skirt the Carried Interest Rules

On February 14, Bloomberg News published an article that quickly made its way around among private investment funds and their lawyers – I received about 10 emails before 9 am from clients. The article discussed a potential structure for general partners of funds (in the article hedge funds, mostly) to […]

Non-US Seller of a Fund Interest? You May Get Taxed!

The recently enacted Tax Cuts and Jobs Act (TCJA) includes a new withholding tax imposed on buyers of partnership interests (including interests in private funds) from non-U.S. sellers where gain on the sale would be taxed to the seller under a separate provision of the TCJA. Under new Section 864(c)(8) […]