On April 5, 2023, the IRS wrapped up its Dirty Dozen 2023 list – earlier than the release of the Dirty Dozen 2022 list which was published on June 10, 2022. According to the IRS, the Dirty Dozen represents the worst of the...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