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Capital Gains Internal Revenue Service Hedge Funds

Locke Lord LLP

Private Equity and Hedge Fund Managers Take Caution - Proposed Treasury Regulations Threaten Management Fee Waivers

Locke Lord LLP on

On July 23, 2015, the Internal Revenue Service ("IRS") issued long-awaited proposed regulations discussing the taxation of management fee arrangements commonly used by private equity funds and their management. The proposed...more

Morgan Lewis

IRS Issues Notices Regarding Certain Structured Transactions

Morgan Lewis on

Parties that enter into “basket option contracts” and “basket contracts” should be aware that the IRS is likely to challenge such transactions and that they have a new obligation to report the transactions to the IRS or face...more

Carlton Fields

IRS Proposes Regulations Directed To “Passive” Hedge Fund Foreign Insurance Entities

Carlton Fields on

On April 24, 2015, the Internal Revenue Service proposed regulations directed to “situations in which a hedge fund establishes a purported foreign reinsurance company in order to defer and reduce the tax that otherwise would...more

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