State Sourcing Income Rules & Considerations for Hedge and Private Equity Funds

As if the Internal Revenue Code, Treasury Regulations and various federal courts didn’t make taxes complicated and confusing enough, hedge fund and private equity managers must also contend with the varied, and often contradictory, state laws regarding sourcing of income. No unifying principle seems to translate from one jurisdiction to the next with one exception:…

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New Fee Disclosure Law Will Increase Compliance Requirement

Private equity and hedge fund managers impacted along with state public pension plans Effective Jan. 1, 2017, California’s newly enacted “fee disclosure law” will significantly increase fee disclosure compliance requirements on state public pension (SPP) plans, as well as the private equity and hedge fund managers that seek their capital. The disclosure requirements are extensive…

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Planning Opportunities for Owners of Passive Foreign Investment Companies

What is a passive foreign investment company (PFIC) and why is it important? To stem a perceived abuse, Internal Revenue Code §§ 1291 to 1298 were enacted in 1986. Without them, a U.S. shareholder of a foreign corporation holding investment-type assets generating current ordinary income such as interest, dividends, royalties or rent could potentially convert…

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The Impact of Investment Strategies of Sovereign Wealth Funds – Presentation Document

Alternatives currently represent over $12 trillion in assets under management, while assets in liquid alternatives are growing rapidly. The CAIA Association Mission: Establish the CAIA designation as the benchmark for alternative investment education worldwide Promote professional development through continuing education, innovative research and thought leadership Advocate high standards of professional ethics Connect industry professionals globally…

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Operational Alpha Series

Over the past year, we have seen vast amount of regulatory pressure being imposed upon the financial services sector, which is forcing banks to look at the risk on their balance sheets. Taking the brunt of this added regulatory burden seems to be emerging fund managers.

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