Hedge Funds

Hedge Funds

Tax Aspects of Hedge Funds

This section examines the special tax issues affecting the general partner and its members; foreign and tax exempt investors; and U.S. individuals. Highlights of the section include a detailed description and analysis of the use of the partnership form by most hedge funds, incentive allocations and fee deferrals to the fund manager (including the implications of new §409A), mark-to-market accounting to establish “book” capital accounts and the resulting tax implications, the use of offshore entities, the deductibility of management fees and other expenses. In addition, this section addresses a range of special tax issues raised by certain types of hedge funds investments, including “loan origination”.


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