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Internal Revenue Service Tax Liability Hedge Funds

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.  
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

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

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

Akin Gump Strauss Hauer & Feld LLP

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

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

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