Carried Interest Rules for Investment Funds: Planning Opportunities and Pitfalls

Mr. Cotler is a partner in the Taxation Group. He advises investment funds, private fund managers, and public and private companies on U.S. federal income tax matters, including partnership, corporate and international tax matters. Mr. Cotler advises on business transactions, securities offerings, structured finance and securitization vehicles, and joint ventures.

Mr. Marotta is a tax attorney in Holland & Knight's Boston office. He assists clients with a range of domestic and international tax issues. Mr. Marotta is experienced in negotiating and structuring the purchase and sale of businesses, negotiating loan agreements for lenders and borrowers, drafting joint venture agreements (including with respect to real estate matters), advising insurers on representation and warranty policy coverage, structuring inbound and outbound investments, forming investment funds, drafting U.S. tax disclosures for private placement memoranda and public offerings, and other issues relating to mergers, acquisitions and reorganizations. He also advises on Section 1202 qualified small business stock (QSBS) issues. Prior to joining Holland & Knight, Mr. Marotta advised private equity and corporate clients on the tax aspects of bankruptcies and domestic and multinational mergers and acquisitions in the New York office of an international law firm. He also has experience providing advice on the structuring of investments in overseas and domestic target companies and other domestic and international tax matters from working in the New York office of an international accounting firm.