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Internal Revenue Service › Offshore Funds › Trusts

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Allen Barron, Inc.

Offshore Real Estate Ownership and Tax Reporting Requirements

Allen Barron, Inc. on

What do you need to know about offshore real estate ownership and any associated tax reporting requirements? Are you a U.S. taxpayer or U.S. resident who owns real estate outside of the United States? It may surprise you to...more

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

Looking Over the Edge of the Cliff– The Use of Pooled Income Funds for the Repatriation of Offshore Carried Interest

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

The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more

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