Informal comments by representatives of the IRS suggested for the first time on June 12, 2009 that investments in certain types of foreign hedge funds may constitute foreign financial acc...
This morning, the Obama Administration provided more detail on its previously announced plan to reform the U.S. tax laws relating to the taxation of income earned by foreign subsidiaries ...
Partners’ interests in a partnership, such as an investment fund, can change during the course of a year as a consequence of transfers and redemptions of interests and the admission of ...
President Obama’s budget proposal, released on February 26, 2009, contained the following line item: “Tax carried interest as ordinary income.” On April 3, Representative Sander Lev...
Bills introduced this week in both the House and the Senate contain two provisions that are of particular significance to hedge funds. One provision would materially alter the tax treatme...
New rules on deferred compensation, enacted as part of the Emergency Economic Stabilization Act of 2008 on October 3, 2008, may have a much broader scope than originally anticipated. Thes...
The Emergency Economic Stabilization Act of 2008 (“EESA”), which President Bush signed on October 3, added Section 457A to the Internal Revenue Code. Under the new provision, managers...
On September 23, 2008, the United States Senate ratified the much anticipated fifth protocol (the “Protocol”) amending the income tax treaty between the United States and Canada.
