The One Big Beautiful Bill Act (OBBBA), which made many significant changes to the U.S. Internal Revenue Code (IRC), has now been in effect for more than a year. A BARBRI program, featuring Kleinberg Kaplan partners Philip S. Gross and Eli A. Shalam and EisnerAmper partner Marc Stahl, examined the changes implemented by OBBBA and their effects on private fund managers and investors. This article, the first in a two-part series, covers their discussion on taxation of performance allocations; the IRC provisions changed by OBBBA affecting management fee waivers; deductions and loss limitations; gains on disposition of qualified small business stock; and income from controlled foreign corporations. The second article will summarize their comments on the fundamental tax-related goals of U.S. taxable investors, non-taxable investors and foreign investors, as well as tax-related fund structuring issues for management and performance fees. For more from Gross, see “Key Tax Issues Fund Managers Must Consider” (Jun. 10, 2021).