More than a year ago, the One Big Beautiful Bill Act (OBBBA) took effect, making significant changes to the U.S. Internal Revenue Code (IRC). Those changes and their impact on private fund managers and their investors were the focus of a BARBRI program featuring Kleinberg Kaplan partners Philip S. Gross and Eli A. Shalam and Eisner Advisory Group LLC partner Marc Stahl. This second article in a two-part series summarizes 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. The first article covered their discussion on taxation of performance allocations as well as 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. See “Does the U.K.’s New Carried Interest Tax Regime Bring Clarity for Hedge Funds?” (Oct. 9, 2025).