
Private Equity: Investment Transactions
We regularly represent our fund clients in a diverse group of industries and asset classes in the the structuring, due diligence, negotiation, and consummation of investments, as well as the post-closing ownership, management, and ultimate disposition of those investments—whether in a successful liquidity event or through a more distressed realization or winding down.
In addition, we also regularly represent not only the funds that provide private capital, but also the companies, management teams, and entrepreneurs who utilize that capital to acquire, create, and grow businesses around the globe.
On Monday, 16 June 2025, the Senate Finance Committee released its version of the Section 899 retaliatory tax provisions that also are included in the “One Big Beautiful Bill Act” that was passed by the House of Representatives on 22 May 2025.
This alert describes the persons who would be subject to the changes contained in Code Section 899, the consequences of being subject to this proposed new Code section, and some of the impacts this provision would have on certain cross-border transactions.
Retaliatory tax provisions contained in H.R. 1, the “One Big Beautiful Bill Act” that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions, including US operations of foreign multinational groups and inbound investments.
The Trump administration has identified growth in the nuclear energy industry as a critical component of the President’s campaign to establish American energy dominance and meet the rapidly increasing need for power.