Gerald Rokoff

Gerald Rokoff

DLA Piper

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Latest Publications


IRS Proposed Tax Regulations Aimed at Fee Waiver Arrangements

The Treasury Department and the Internal Revenue Service have issued proposed regulations addressing disguised payment for services of a partner, including the proper tax treatment of fee waiver arrangements commonly used by...more

7/31/2015 - Fee Waivers Fund Managers Investment Funds IRS Partnerships Private Equity Private Equity Funds Profits Interests Safe Harbors Section 409A Section 457A U.S. Treasury

Proposed US Tax Legislation Aims to Curb Hedge Fund Reinsurance

Senator Ron Wyden (D-OR) has released legislation, the Offshore Reinsurance Tax Fairness Act (ORTFA), which aims to close what he perceives to be a loophole used to exploit an exception to the passive foreign investment...more

7/6/2015 - Corporate Taxes Financial Reporting GAAP Hedge Funds Insurance Industry Internal Revenue Code (IRC) Investment Funds IRS Offshore Companies Passive Foreign Investment Company Proposed Legislation Reinsurance SPVs Tax Deferral U.S. Treasury

District court finds that insurance premium excise tax does not apply to retrocession transactions

On February 5, 2014, the US District Court for the District of Columbia held that the federal excise tax ("the FET") on insurance and reinsurance premiums does not apply to retrocession insurance transactions. Under a plain...more

2/7/2014 - Casualty Insurance Excise Tax Federal Taxes Indemnity Insurance Reinsurance Retrocessional Claims

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