News & Analysis as of

Hedge Funds Capital Gains

Robins Kaplan LLP

Financial Daily Dose 8.22.2019 | Top Story: CBO Projects $1 Trillion Annual US Deficit in 2020

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The CBO sent shivers down the spines of deficit hawks yesterday with its latest forecast that shows federal cost overruns hitting $1 trillion for fiscal 2020, an increase of more than $100 billion from projections just 3...more

Foley & Lardner LLP

U.S. PFIC Taxation Exemption to be Narrowed?

Foley & Lardner LLP on

The last 15 years have seen the advent of a new reinsurance platform, where hedge funds have sponsored non-U.S. reinsurers, who in turn invest their capital in the sponsoring hedge funds. While there are business rationales...more

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

Dechert LLP

Starting a Hedge Fund in 2015

Dechert LLP on

Hedge funds are well into the transition from bastions of alternative investment to being accepted into the mainstream investment marketplace. It is now estimated that global hedge fund assets under management amount to in...more

Eversheds Sutherland (US) LLP

Legal Alert: Camping on "The Street": A First Step in the Reform of the Taxation of Financial Instruments and Products

On January 24, House Ways and Means Committee Chairman Camp (R-MI) released a discussion draft of proposals to reform the taxation of certain financial instruments and products (the Camp Draft). In brief, the Camp Draft: ...more

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