United States Federal Income Tax Treatment Of Hedge Funds Their Investors And Their Managers

U.S. investors are often confronted with the issue of investing in an offshore investment vehicle and hedge fund managers are often confronted with the issue of whether to set up a domestic fund, an offshore fund or both. Generally, U.S. tax-exempt investors and foreign investors invest in a manager's parallel offshore hedge fund or offshore feeder fund which is classified as a corporation for U.S. federal income tax purposes. Conventional wisdom is that U.S. taxable investors invest in the manager's parallel domestic fund or domestic feeder fund which is classified as a partnership for U.S. federal income tax purposes. But conventional wisdom is not always wise. This article discusses the tax issues that a U.S. investor should consider when investing in an offshore fund (and as a corollary what a hedge fund manager should consider when structuring his or her funds) with a particular focus on the various PFIC (i.e., passive foreign investment company) elections potentially available to a U.S. investor and highlights the potential affirmative tax benefits, although somewhat counterintuitive, of U.S. investors investing in offshore funds rather than in domestic funds.

A new, lucid approach to the formulation of accounting policies for tax reporting Unraveling the layers of complexity surrounding the formulation of accounting policies for tax reporting, Taxation of US Investment Partnerships and Hedge Funds: Accounting Policies, Tax Allocations and Performance Presentation enables your corporation to implement sound up-front accounting and tax policies in order to reduce the overall cost of CFO and legal functions within a U.S. Investment partnership. Understand the pitfalls and optimize across legitimate policies that are consistent with the IRS regulations Presents a clear roadmap for accounting, tax policies, tax filing and performance presentation for US investment partnerships and hedge funds Providing tremendous understanding to a complex topic, Taxation of US Investment Partnerships and Hedge Funds is guaranteed to demystify the inner workings of the formulation of accounting policies for tax reporting.

This authoritative resource surveys federal securities laws and rules applicable to the organization, capitalization and operations of private U.S. domestic investment partnerships that invest and trade mainly in the public securities markets. Includes a detailed index.

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The book analyses the taxation of investment funds and their investors from the standpoint of domestic tax laws, tax treaties and EC law. It also provides a comprehensive understanding of the tax issues arising in the cross-border transactions of investment funds and private fund investors in the European Union. The viewpoints of the source state of income, residence state of the investment fund as well as the residence state of the investor are all considered. The book takes a comparative approach by covering five EU Member States (the United Kingdom, Germany, France, Luxembourg and Finland). On the basis of the examination at the Member State level, the present tax rules and practices are tested against the fundamental freedoms of the EC Treaty. The conclusion is that there are still various tax measures that are likely to be in conflict with EC law. The book also discusses possibilities of adopting targeted measures of positive integration at the level of the European Union with a view to enhancing the objective of the single investment fund market.