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Proskauer Rose LLP

Proskauer's Hedge Start: Key Structuring Issues

Proskauer Rose LLP on

A key initial decision for a manager launching a new hedge fund is to decide between: A “master-feeder” fund structure: In a typical “master-feeder” structure, an onshore “feeder” fund and an offshore “feeder” fund both...more

Proskauer Rose LLP

Proskauer’s Hedge Start: Key Tax Issues

Proskauer Rose LLP on

Different hedge fund investors have different tax concerns that must be taken into account when structuring a hedge fund and its portfolio investments. Hedge fund investors generally fall into three categories:...more

Conyers

ケイマン諸島プライベートエクイティ/ベンチャーキャピタル/不動産ファンドの設立

Conyers on

ファンドの 投資家 がファンドに対して償還 請求権を有するオープンエンド型ファンドは、 流動性 のある 資産に投資するヘッジファンド等ファンド に適している一方、プライベートエクイティ、ベンチャーキャピタル、不動産等の非流動資産に投資するファンドは、投資が実現するまでにより多くの時間を必要とし、クローズドエンド型ストラクチャーが適しています。...more

Seward & Kissel LLP

Building a Scalable Hedge Fund Business

Seward & Kissel LLP on

As new portfolio managers enter the hedge fund space with dreams of running billions of dollars in a traditional US/offshore master-feeder structure, many of these managers are encountering the asset raising headwinds that...more

Conyers

BVI Hybrid Funds

Conyers on

In this series of articles we consider two of the more common requests we see in terms of fund structuring options: Multi-Class Funds, and Hybrid Funds. This second article in the series will consider Hybrid Funds....more

Conyers

BVI Multi-Class Funds

Conyers on

In this series of articles we consider two of the more common requests we see in terms of fund structuring options: Multi-Class Funds, and Hybrid Funds. This first article in the series will consider Multi-Class Funds. Hybrid...more

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

THE WAY WE WERE

Using the Loan Method of Split Dollar to recreate the benefit of tax deferral for Hedge Fund Managers in lieu of carried interest in their offshore fund.#splitdollar #ppli #estateplanning #financialadvisors #finance...more

Ballard Spahr LLP

United States “Beats” Switzerland as a Perceived Global Haven for Money Laundering and Tax Evasion

Ballard Spahr LLP on

The Cayman Islands Receive “Top Honors.”  But, Global Financial Transparency is Reportedly Improving in General - The United States has overtaken Switzerland as a financial secrecy haven, according to the latest rankings –...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

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

Looking Over the Edge of the Cliff– The Use of Pooled Income Funds for the Repatriation of Offshore Carried Interest

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

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

Split-dollar Life Insurance – A Tax-Leveraged Derivative for Hedge Fund Managers

The Emergency Economic Stabilization Act of 2008 ended the not so discrete secret of hedge fund managers, the deferred compensation arrangement with their offshore funds or as the New York Times described, “an unlimited Super...more

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

Can We Talk? Providing Hedge Fund Managers with the Deferral of Carried Interest until Eternity

Overview - The recent passing of Joan Rivers not only requires us to pay tribute to one of the great comedic minds of the last forty-fifty years, but serves as a testimony to professional passion, perseverance and hard...more

Dechert LLP

Financial Services Quarterly Report - Fourth Quarter 2013: UK Autumn Statement Brings Mixed Blessings

Dechert LLP on

This year’s Autumn Statement delivered by the Chancellor of the Exchequer in Parliament on 5 December 2013, and the subsequent draft Finance Bill and H.M. Revenue & Customs (HMRC) and H.M. Treasury press releases of 10...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

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