Taxing Life Settlements Investment Funds Under The TCJA

By Brian Casey, Thomas Sherman and Jaremi Chilton (May 15, 2018, 3:19 PM EDT) -- This is the third article in our series of three articles addressing the most significant impacts of the Tax Cuts and Jobs Act on the U.S. life settlements industry. Life settlements investment funds, like hedge funds and private equity funds, usually have general partners whose compensation for managing the fund oftentimes includes a so-called "carried interest" profit participation element. Among its many other changes, the TCJA materially altered the taxation of carried interests generally, but not, for the most part, for life settlements investment funds.

Prior to the TCJA, the profits realized from these carried interests by general partners were taxed...

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