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Tax Planning Hedge Funds

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

Wilson Sonsini Goodrich & Rosati

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

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

Lowenstein Sandler LLP

Hedge Fund Guy and the Terrible, Horrible, No Good Very Bad Statue

Lowenstein Sandler LLP on

Host Warren K. Racusin, partner and Chair of Lowenstein’s Trusts & Estates practice, talks about how to incorporate charitable giving into your estate plan. Partner Leslie P. Adamo, Vice Chair of the firm’s Tax group,...more

Freeman Law

Hedge Funds 101: An Introduction to Tax Issues

Freeman Law on

Hedge Funds and Taxes - Hedge funds provide a vehicle to pool private capital for investment in stocks, securities and financial derivatives. While hedge funds take on many different structures—including master-feeder,...more

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

THE WAY WE WERE

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

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

THE WAY WE WERE

Nowotny On Death and Taxes, episode #20, The Way We Were is about using the Loan Method of Split Dollar to recreate the benefit of tax deferral for hedge fund managers. #splitdollar #ppli #hedgefundmanagers #estateplanning...more

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

THE WAY WE WERE - Using Loan Method Split Dollar to Recreate the Benefit of Tax Deferral for Carried Interest

Hedge Fund managers previously had an unprecedented ability to defer their carried interest in the offshore hedge funds that they manage. IRC Sec. 409A put an end to those deferrals and required hedge fund managers to...more

Troutman Pepper Locke

Investment Management Roundtable Discussion – Personal Estate Planning

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Gregory J. Nowak, a partner and practice leader for hedge funds in Pepper Hamilton’s Private Fund Services Practice Group, hosts a series of candid, interactive webinar discussions for West LegalEdcenter on what is going on...more

Troutman Pepper Locke

Investment Management Update – Exit Strategies

Troutman Pepper Locke on

Gregory J. Nowak, a partner and practice leader for hedge funds in Pepper Hamilton’s Funds Services Practice Group, hosts a monthly webinar series for West LegalEdcenter. This month, Mr. Nowak, is joined by Richard Juliano,...more

Troutman Pepper Locke

Investment Management Update – Exit Strategies (PowerPoint Slides)

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Gregory J. Nowak, a partner and practice leader for hedge funds in Pepper Hamilton’s Funds Services Practice Group, hosts a monthly webinar series for West LegalEdcenter. This month, Mr. Nowak, is joined by Richard Juliano,...more

Williams Mullen

IRS Gets “Bageled” in Tax Court Over Family Office Expenses

Williams Mullen on

A recent case, Lender Management LLC v. Commissioner of Internal Revenue, T.C. Memo. 2017-246, has created a window of opportunity for family offices to restructure their affairs and potentially deduct certain family office...more

Proskauer - Tax Talks

Tax Planning Under the Tax Cuts and Jobs Act: Flow-Throughs Are the Answer to Everything

Proskauer - Tax Talks on

The tax reform bills introduced in the House of Representatives and the Senate dramatically reduce the corporate tax rate from 35% to 20% and create added incentives for taxpayers to invest capital into U.S. businesses with...more

Troutman Pepper Locke

ALJ Forces Combination of Hedge Fund Group in New York City - Tax Update Volume 2017, Issue 4

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On April 27, the New York City Tax Appeals Tribunal issued a decision requiring the related members of a hedge fund group to file a combined return for New York City tax purposes. However, the administrative law judge (ALJ)...more

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