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Exemptions › Charitable Donations › Internal Revenue Service

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

Looking over the edge of the Cliff - The Use of Pooled Income Funds to Reduce the Taxation of Offshore Repatriated Carried...

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

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

Morrison & Foerster LLP

New Tax Act Provides Long-Awaited Clarity and Certainty on Estate, Gift and Generation-Skipping Transfer Taxes, and Income Tax...

Morrison & Foerster LLP on

On January 1, 2013, the Senate and the House of Representatives passed the American Taxpayer Relief Act of 2012 (ATRA), averting the so-called “fiscal cliff.” The legislation, which was signed by President Obama on January 2,...more

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