Fund Taxation in Corporate Modernization Act - Practical Considerations on the New Check-the-box Procedure for Partnerships

As a result of the new option model applicable as of 01.01.2022, partnerships can be treated like corporations for corporate income tax purposes upon application. Fund taxation is also affected by this. Jens Steinmüller and André Blischke highlight the interfaces between the check-the-box procedure introduced by the Corporate Income Tax Modernization Act (KöMoG) and fund taxation, address potential problems in connection with fund set-up and investment, and provide initial structural considerations facing initiators and investors in the future.