Thomson Reuters Session 2: Investment Management, Hedge Funds and Registered Mutual Funds: What's Happening Now?
Stealth Lawyer: Eli Broverman, Financial Startup Co-Founder
The Office of Chief Counsel of the Internal Revenue Service (the "IRS") recently issued internal guidance in the form of a Chief Counsel Advice (the "CCA") indicating that the IRS has taken the position that the "limited...more
A recent response by the Internal Revenue Service Chief Counsel (CCA) to an inquiry from one of its field office agents addressed the question of whether management fees earned by an investment manager organized as a limited...more
In a case of first impression, Frank Aragona Trust v. Commissioner, 142 T.C. No. 9 (Mar. 27, 2014), the Tax Court held that a trust could materially participate in a trade or business based upon the activities of the...more
Pepper partner Gregory J. Nowak has regularly hosted a roundtable in Pepper’s New York office for private funds and their managers to discuss issues in the investment management world. He has recently started to give a...more
Following the execution of an inter-governmental agreement (or “IGA”) with the United States in September 2012 and a consultation exercise which closed in late 2012, HM Revenue & Customs (“HMRC”) recently published draft...more
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