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Hedge Funds › Income Taxes › Carried Interest

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

Skadden, Arps, Slate, Meagher & Flom LLP

A Guide to the UK Disguised Investment Management Fee Rules

Skadden, Arps, Slate, Meagher & Flom LLP on

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

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