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Results: 1-10 of 22

Variable prepaid forward contracts: sale or no sale that is the question

  • Alston & Bird LLP
  • -
  • USA
  • -
  • March 1 2007

The IRS Office of Associate Chief Counsel (Financial Instruments and Products) issued Generic Legal Advice memorandum AM 2007-004 (“Legal Advice”) addressing variable prepaid forward (“VPF”) contracts

IRS guidance issued on characterization of fund of funds management fees implications for master-feeder hedge fund structures

  • Alston & Bird LLP
  • -
  • USA
  • -
  • July 23 2008

Earlier this month, the IRS issued guidance that may require hedge fund managers to choose between taking their management fees out at the master fund level or denying the funds’ partners a tax deduction for such fees

IRS scrutinizes derivatives used by hedge funds

  • Alston & Bird LLP
  • -
  • USA
  • -
  • October 15 2007

The Internal Revenue Service continues its scrutiny of the favorable tax treatment currently afforded to hedge funds and private equity firms

Tax issues facing investors in Bernard Madoff’s fund

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 1 2009

The tax laws may give investors defrauded by Mr. Madoff and his firm, Bernard Madoff Investment Securities LLC, a method for recovering some of the money they have lost, but the uncertainty and complexity of the rules may lead to disputes with the Internal Revenue Service (IRS

Additional deadline for voluntary disclosure program

  • Alston & Bird LLP
  • -
  • USA
  • -
  • November 16 2009

The IRS is considering imposing a deadline on information reports filed by individuals who have sought to voluntarily disclose assets held in offshore accounts before the special program deadline

U.S. lawmakers introduce Foreign Account Tax Compliance Act of 2009

  • Alston & Bird LLP
  • -
  • USA
  • -
  • November 16 2009

On October 27, 2009, Senator Max Baucus (D-MT) and Representative Charles Rangel (D-NY) introduced the Foreign Account Tax Compliance Act of 2009 (H.R. 3933, S. 1934) (the “Bill”) in the U.S. Congress

House passes bill changing taxation of carried interests

  • Alston & Bird LLP
  • -
  • USA
  • -
  • May 31 2010

On Friday, by a 215-204 vote, the House passed the 2010 tax extenders bill, H.R. 4213, the American Workers, State, and Business Relief Act of 2010, that would, if also approved by the Senate, significantly change the taxation of carried interests in certain investment partnerships (including hedge funds, venture capital funds and private equity funds, but not certain partnerships controlled by real estate investment trusts

Treasury relaxes test for re-testing debt status

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 9 2010

The troubled economic times have required many modifications of distressed debt instruments

Senator Scott Brown declares opposition to $19 billion "bank tax"; House-Senate conference may reconvene

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 29 2010

Today, Senator Scott Brown (R-MA), one of the few Republicans to vote for passage of the financial reform bill, sent a letter to Senate Banking Committee Chairman Christopher Dodd (D-CT) and House Financial Services Committee Chairman Barney Frank (D-MA) declaring his opposition to the roughly $19 billion "bank tax" on large banks and hedge funds that is included in the recently reconciled Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act

IRS provides guidance on NOL limitations

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 25 2010

Federal income tax laws have long imposed limits on the future deductibility of corporate net operating losses if the corporation experiences a substantial change of ownership, to prevent "trafficking in losses."

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