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Income Taxes › Hedge Funds

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
ASKramer Law

Tax-Loss Harvesting Part III: Investment Strategies

ASKramer Law on

Taxpayers invest to make money and hope to earn a decent return on their investments. Tax-loss harvesting can be used as part of a taxpayer’s overall investment strategy without affecting investment  returns, while offsetting...more

Cadwalader, Wickersham & Taft LLP

Tax Court Calls Bluff on Hedge Fund’s Basket Option Contracts

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The Tax Court recently held that a hedge fund’s basket option contracts were in substance tax ownership of the underlying basket securities. The hedge fund, through its affiliated entities, entered into 10 basket option...more

Pillsbury Winthrop Shaw Pittman LLP

Vindication: The U.S. Tax Court Sustains IRS Position on Basket Options in GWA, LLC

Pillsbury Winthrop Shaw Pittman LLP on

In Advice Memorandum 2010-005, the Internal Revenue Service (IRS) set out its position that “basket options” conveyed so many attributes of ownership over the securities referenced in these options to the optionee that the...more

Cadwalader, Wickersham & Taft LLP

Should I Stay or Should I Go? Hedge Funds: Crypto and State Tax

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Hedge fund managers have a state tax gating issue when it comes to adding crypto to their assets under management. Generally, states such as New York, Connecticut and California encourage asset managers to locate in their...more

Wilson Sonsini Goodrich & Rosati

The New One-Percent Excise Tax on Stock Repurchases and Its Potential Implications for Convertible Bond Hedge Transactions and...

Wilson Sonsini Goodrich & Rosati on

On August 12, 2022, the U.S. House of Representatives approved H.R. 5376, the "Inflation Reduction Act" (the Act), which was signed into law by President Biden on August 16, 2022. The approval and subsequent enactment follow...more

Rivkin Radler LLP

Biden’s 2022 Revenue Proposal, Profits Interests, And The Alchemy Of Compensation

Rivkin Radler LLP on

Recap- Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held...more

ArentFox Schiff

Angel Investor Tax Credit Guidance Issued by Massachusetts Department of Revenue

ArentFox Schiff on

On July 24, the Massachusetts Department of Revenue (DOR), in collaboration with the Massachusetts Life Sciences Center (MLSC) and the Executive Office of Housing and Economic Development, promulgated Regulation 830 CMR...more

Akin Gump Strauss Hauer & Feld LLP

Considerations for Asian Fund Managers under the U.S. New Partnership Audit Regime

Akin Gump Strauss Hauer & Feld LLP on

The Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, resulted in a fundamental change in the way the U.S. Internal Revenue Service (IRS) will conduct audits of collective...more

Katten Muchin Rosenman LLP

Tax Reform: Hedge Funds/Commodity Funds/Fund Managers

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House Republicans released their draft tax bill on November 2, representing their opening bid in the drive to reach agreement on a comprehensive tax reform bill that can be presented to the House for a vote before the...more

Troutman Pepper

Fund Managers, Welcome to the Hotel California - When It Comes to Certain Taxes, It's Possible You Can Never Leave - Tax Update...

Troutman Pepper on

Fund Managers May Be Taxable in California, Even if the Manager Has No Property or Payroll in California and All of the Management Services Are Performed Outside of the State. Several recent law changes in California,...more

Skadden, Arps, Slate, Meagher & Flom LLP

A Guide to the UK Disguised Investment Management Fee Rules

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New rules effective from today in the U.K. are likely to have material impact on the tax treatment of payments by a fund to its U.K.-based management executives and service providers. The rules cover many areas of fund...more

Stinson - Corporate & Securities Law Blog

Hedge Fund COO Makes Admissions in SEC Settlement

Stinson - Corporate & Securities Law Blog on

The SEC announced that the former Chief Operating Officer at Harbinger Capital Partners LLC has agreed to settle allegations that he assisted a scheme by the firm and its owner to misappropriate millions of dollars from a...more

Foley Hoag LLP

New Proposals to Tax Carried Interest as Ordinary Income Garner Bipartisan Support

Foley Hoag LLP on

On March 4, 2014, President Obama issued his Administration’s Fiscal Year 2015 Budget, which includes a proposal to tax carried interests (also known as “performance allocations” or “incentive allocations”) in investment...more

Gerald Nowotny - Law Office of Gerald R....

In the Money – Puerto Rico Me Encanta! Puerto Rican Hedge Funds

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Overview - Every financial media outlet (including Bloomberg and the Wall Street Journal) in the last several weeks has run an article on the possibility of billionaire hedge fund manager becoming a Puerto Rican...more

Eversheds Sutherland (US) LLP

Legal Alert: Camping on "The Street": A First Step in the Reform of the Taxation of Financial Instruments and Products

Eversheds Sutherland (US) LLP on

On January 24, House Ways and Means Committee Chairman Camp (R-MI) released a discussion draft of proposals to reform the taxation of certain financial instruments and products (the Camp Draft). In brief, the Camp Draft: ...more

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