News & Analysis as of

Hedge Funds Income Taxes

Cadwalader, Wickersham & Taft LLP

Should I Stay or Should I Go? Hedge Funds: Crypto and State Tax

Hedge fund managers have a state tax gating issue when it comes to adding crypto to their assets under management. Generally, states such as New York, Connecticut and California encourage asset managers to locate in their...more

Wilson Sonsini Goodrich & Rosati

The New One-Percent Excise Tax on Stock Repurchases and Its Potential Implications for Convertible Bond Hedge Transactions and...

On August 12, 2022, the U.S. House of Representatives approved H.R. 5376, the "Inflation Reduction Act" (the Act), which was signed into law by President Biden on August 16, 2022. The approval and subsequent enactment follow...more

Rivkin Radler LLP

Biden’s 2022 Revenue Proposal, Profits Interests, And The Alchemy Of Compensation

Rivkin Radler LLP on

Recap- Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held...more

ArentFox Schiff

Angel Investor Tax Credit Guidance Issued by Massachusetts Department of Revenue

ArentFox Schiff on

On July 24, the Massachusetts Department of Revenue (DOR), in collaboration with the Massachusetts Life Sciences Center (MLSC) and the Executive Office of Housing and Economic Development, promulgated Regulation 830 CMR...more

Akin Gump Strauss Hauer & Feld LLP

Considerations for Asian Fund Managers under the U.S. New Partnership Audit Regime

The Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, resulted in a fundamental change in the way the U.S. Internal Revenue Service (IRS) will conduct audits of collective...more

Katten Muchin Rosenman LLP

Tax Reform: Hedge Funds/Commodity Funds/Fund Managers

House Republicans released their draft tax bill on November 2, representing their opening bid in the drive to reach agreement on a comprehensive tax reform bill that can be presented to the House for a vote before the...more

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...

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

Troutman Pepper

Fund Managers, Welcome to the Hotel California - When It Comes to Certain Taxes, It's Possible You Can Never Leave - Tax Update...

Troutman Pepper on

Fund Managers May Be Taxable in California, Even if the Manager Has No Property or Payroll in California and All of the Management Services Are Performed Outside of the State. Several recent law changes in California,...more

Skadden, Arps, Slate, Meagher & Flom LLP

A Guide to the UK Disguised Investment Management Fee Rules

New rules effective from today in the U.K. are likely to have material impact on the tax treatment of payments by a fund to its U.K.-based management executives and service providers. The rules cover many areas of fund...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

Stinson - Corporate & Securities Law Blog

Hedge Fund COO Makes Admissions in SEC Settlement

The SEC announced that the former Chief Operating Officer at Harbinger Capital Partners LLC has agreed to settle allegations that he assisted a scheme by the firm and its owner to misappropriate millions of dollars from a...more

Foley Hoag LLP

New Proposals to Tax Carried Interest as Ordinary Income Garner Bipartisan Support

Foley Hoag LLP on

On March 4, 2014, President Obama issued his Administration’s Fiscal Year 2015 Budget, which includes a proposal to tax carried interests (also known as “performance allocations” or “incentive allocations”) in investment...more

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

In the Money – Puerto Rico Me Encanta! Puerto Rican Hedge Funds

Overview - Every financial media outlet (including Bloomberg and the Wall Street Journal) in the last several weeks has run an article on the possibility of billionaire hedge fund manager becoming a Puerto Rican...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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