US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
THE WAY WE WERE
BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
Hong Kong’s status as an open jurisdiction offers hedge fund managers unparalleled flexibility to choose the domicile of their fund structure, free from restrictive local mandates. This allows managers to align their fund’s...more
A key initial decision for a manager launching a new hedge fund is to decide between: A “master-feeder” fund structure: In a typical “master-feeder” structure, an onshore “feeder” fund and an offshore “feeder” fund both...more
Different hedge fund investors have different tax concerns that must be taken into account when structuring a hedge fund and its portfolio investments. Hedge fund investors generally fall into three categories:...more
ファンドの 投資家 がファンドに対して償還 請求権を有するオープンエンド型ファンドは、 流動性 のある 資産に投資するヘッジファンド等ファンド に適している一方、プライベートエクイティ、ベンチャーキャピタル、不動産等の非流動資産に投資するファンドは、投資が実現するまでにより多くの時間を必要とし、クローズドエンド型ストラクチャーが適しています。...more
As new portfolio managers enter the hedge fund space with dreams of running billions of dollars in a traditional US/offshore master-feeder structure, many of these managers are encountering the asset raising headwinds that...more
In this series of articles we consider two of the more common requests we see in terms of fund structuring options: Multi-Class Funds, and Hybrid Funds. This second article in the series will consider Hybrid Funds....more
In this series of articles we consider two of the more common requests we see in terms of fund structuring options: Multi-Class Funds, and Hybrid Funds. This first article in the series will consider Multi-Class Funds. Hybrid...more
Using the Loan Method of Split Dollar to recreate the benefit of tax deferral for Hedge Fund Managers in lieu of carried interest in their offshore fund.#splitdollar #ppli #estateplanning #financialadvisors #finance...more
The Cayman Islands Receive “Top Honors.” But, Global Financial Transparency is Reportedly Improving in General - The United States has overtaken Switzerland as a financial secrecy haven, according to the latest rankings –...more
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
The Emergency Economic Stabilization Act of 2008 ended the not so discrete secret of hedge fund managers, the deferred compensation arrangement with their offshore funds or as the New York Times described, “an unlimited Super...more
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