Joel Almquist

Joel Almquist

K&L Gates LLP

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Federal Tax Guidance Regarding RICs’ Investments in Commodities, Certain PFICs, and “Securities”

The Treasury Department (Treasury) and the Internal Revenue Service (Service) recently issued proposed regulations that, if finalized as proposed, could have a significantly adverse effect on the ability of a regulated...more

10/10/2016 - CFC Investment Company Act of 1940 IRS PFIC Proposed Regulation RICs U.S. Treasury

IRS Guidance Regarding Money Market Mutual Funds

On July 23, 2014, the Securities and Exchange Commission adopted amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended, governing the structure and operation of money market mutual funds (MMFs). ...more

5/17/2016 - Floating NAV IRS MMF Money Market Funds

Permanent U.S. Withholding Tax Rules for Non-US Investors in RICs – A New Distribution Opportunity

U.S.-registered investment companies (“RICs”) historically have had limited success attracting investments from non-U.S. investors, in large part due to U.S. withholding taxes on fund distributions. This has allowed funds...more

1/13/2016 - Foreign Investment Fund Distribution New Legislation Protecting Americans from Tax Hikes (PATH) Act Registered Investment Companies (RICs) Withholding Tax

Ninth Circuit Opinion May Open Litigation Doors Most Thought Closed

A recent Ninth Circuit Court of Appeals opinion charts potential new pathways for claims for damages resulting from portfolio losses by mutual fund shareholders against both a fund’s trustees and its investment adviser....more

3/20/2015 - Breach of Contract Breach of Duty Fiduciary Duty Investment Adviser Shareholders Third-Party Beneficiaries Trustees

New IRS Revenue Ruling 2014-18 and the Use of Hedge Fund Stock Options

The Internal Revenue Service has issued Revenue Ruling 2014-18 (the “Ruling”) to clarify that stock options and stock-settled stock appreciation rights (“SARs”), properly designed, can be used as a form of compensation to...more

6/13/2014 - Compensation & Benefits Deferred Compensation Hedge Funds Internal Revenue Code (IRC) IRS SAR Section 457A

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