Meeting today’s asset management tax challenges

 

Get specialized insights in this podcast series

 

Asset managers have encountered numerous new tax challenges in recent years, necessitating new strategies to minimize the tax burden across the industry’s various sectors.

 

Depending on your organization, issues such as legal entity structuring, the deductibility of interest expenses, the capitalization of research expenditures, state and local taxes, global minimum tax rates and other considerations may affect your current tax planning.

 

In this podcast series, Grant Thornton Advisors LLC Asset Management Tax Leader Eric Coombs discusses recent and evolving tax trends in the industry with the firm’s asset management tax specialists.

 

 

 

Navigating international tax challenges: Insights on the YA Global case and Pillar 2

 

Some of the current international tax challenges for asset management firms are related to the U.S. Tax Court’s ruling in favor of the government in the YA Global case and the new Pillar 2 global minimum tax requirements.

 

Asset managers may wish to carefully review the Tax Court’s ruling that YA Global was engaged in a U.S. trade or business and was a dealer in securities. Although the case’s fact patterns were unique, they may prompt a closer look at fee-sharing arrangements. “I don’t think this case upsets those arrangements in most cases, but I do think it’s worth a fresh look, particularly if you have a unique fee-sharing arrangement,” said Cory Perry, a Principal in the Washington National Tax Office for Grant Thornton Advisors LLC.

 

Meanwhile, Pillar 2 introduces a global minimum tax of 15% for large entities with at least $750 million in consolidated global revenue that are subject to tax in at least two jurisdictions. While the United States hasn’t yet adopted Pillar 2, many other countries — particularly in the European Union — are moving forward with the regulation.

 

Perry and Coombs discuss these international tax issues in detail in this episode.

 

12:53 | Transcript

 

 

 

Tax strategies and regulatory insights for private equity funds

 

In this episode, we discuss private equity with Melanie Krygier, M&A Tax Leader for Grant Thornton Advisors LLC. We explore how some PE portfolio companies have been adversely affected by Section 163(j), which governs interest expense deductibility, and Section 174, which requires capitalization of research and development costs.

 

Krygier said some portfolio companies might respond to the 163(j) challenge by capitalizing interest expense into other assets. “It might actually provide an opportunity to attract some of those interest costs to those other assets, which could either be depreciable, amortizable, or deductible in the current year,” she said.

 

Listen as Krygier and Coombs discuss other PE considerations, including additional regulatory and tax reporting requirements at the fund level that have further drained resources.

 

7:13 | Transcript

 

 

 

Effective tax planning for private credit and collateralized loan obligations

 

Private credit has become an increasingly popular asset class in the past two years as high interest rates constrained bank lending. These private funds require careful structuring upfront to minimize the taxes that investors will pay on interest income. “Because this private credit market is booming in recent years, it’s really important to have appropriate tax planning done at the outset,” said Satish Katikala, Partnership Tax Solutions Senior Manager for Grant Thornton Advisors LLC.

 

In this podcast episode, listen as Coombs and Katikala describe the tax considerations for private credit as well as for collateralized loan obligations (CLOs), which are often formed in jurisdictions outside the United States and may run the risk of triggering effectively connected income tax when there is a debt-to-equity restructuring by the borrowers.

 

9:24 | Transcript

 

 

 

Leveraging analytics for tax efficiency in asset management firms

 

As asset management firms work to comply with these new and changing regulations — as well as existing rules — data analytics may provide substantial advantages for firms’ compliance efforts. Tara Soileau, a Transaction Advisory Managing Director for Grant Thornton Advisors LLC, cited sales tax treatment of employee purchasing as one example.

 

“We use data and analytics to pinpoint taxable versus nontaxable vendors, for example, and quantify very specific segments of purchasing that are relevant to a tax diligence scenario, such as sales and use tax, as well as employee classifications and classifications of employee spend,” Soileau said.

 

Listen as Soileau and Coombs discuss this and other perspectives on data and analytics in this podcast episode.

 

8:17 | Transcript

 
 

Contacts:

 
 
 
Cory Perry

Washington DC, Washington DC

Industries
  • Manufacturing, Transportation & Distribution
  • Technology, media & telecommunications
  • Private equity
Service Experience
  • Tax
 
 
 
Content disclaimer

This Grant Thornton Advisors LLC content provides information and comments on current issues and developments. It is not a comprehensive analysis of the subject matter covered. It is not, and should not be construed as, accounting, legal, tax, or professional advice provided by Grant Thornton Advisors LLC. All relevant facts and circumstances, including the pertinent authoritative literature, need to be considered to arrive at conclusions that comply with matters addressed in this content.

Grant Thornton Advisors LLC and its subsidiary entities are not licensed CPA firms.

For additional information on topics covered in this content, contact a Grant Thornton Advisors LLC professional.

 

 

Tax professional standards statement

This content supports Grant Thornton Advisors LLC’s marketing of professional services and is not written tax advice directed at the particular facts and circumstances of any person. It is not, and should not be construed as, accounting, legal, tax, or professional advice provided by Grant Thornton Advisors LLC. If you are interested in the topics presented herein, we encourage you to contact a Grant Thornton Advisors LLC tax professional. Nothing herein shall be construed as imposing a limitation on any person from disclosing the tax treatment or tax structure of any matter addressed herein.

The information contained herein is general in nature and is based on authorities that are subject to change. It is not, and should not be construed as, accounting, legal, tax, or professional advice provided by Grant Thornton Advisors LLC. This material may not be applicable to, or suitable for, the reader’s specific circumstances or needs and may require consideration of tax and nontax factors not described herein. Contact a Grant Thornton Advisors LLC tax professional prior to taking any action based upon this information. Changes in tax laws or other factors could affect, on a prospective or retroactive basis, the information contained herein; Grant Thornton Advisors LLC assumes no obligation to inform the reader of any such changes. All references to “Section,” “Sec.,” or “§” refer to the Internal Revenue Code of 1986, as amended.

Grant Thornton Advisors LLC and its subsidiary entities are not licensed CPA firms.

 

Our fresh thinking