Readers, we are continuing to follow along with the saga between Senator Ron Wyden (former Chair of the Senate Finance Committee) and IRS Commissioner, John Koskinen, regarding hedge fund sponsored reinsurance companies which I’ve written about before here. Inside of the promised 90-day deadline, on April 23, 2015, the Department […]
After months of back and forth between Senator Ron Wyden (D-Ore.) and John Koskinen, the Commissioner of the IRS, regarding hedge fund reinsurance, the Commissioner has vowed to produce further IRS guidance. On February 3, 2015, the Commissioner told Senator Wyden that he would produce guidance within 90 days. Over […]
Long-term investing is important for just about everyone, and it can become a complicated process for most people who are looking for the best way to structure their retirement and supplemental income. There are many different ways to invest, and many different fees associated with those investments. Each investor has […]
Some broker-dealers are providing research services to their clients where the client ultimately decides if and when to pay, and how much they should pay. Because of this structure, the recording of the revenue for the broker-dealer can be a little tricky. Should the revenue just be recorded when it […]
As with any niche or industry, the alternative investment industry has its own terminology. In fact, it would be almost impossible to understand a private placement memorandum or subscription document without familiarizing one’s self with this industry specific verbiage. Below are some specific terms that are consistently used in the […]
The IRS recently took a shot across the bow of limited partners of investment management companies with respect to the application of self-employment tax (or, SE tax, for short). In fact, the ruling could potentially affect limited partners (including LLC / LLP partners) in every industry. While this tax issue has been fought on several levels over the past 20 or more years, it had gone dormant since 1997. Now, an IRS Chief Counsel Advice (ILM 201436049 (05/20/2014)), released on September 5, 2014, (the “ILM”) demonstrates that the IRS may be ready to renew the fight.
In late July, Treasury Secretary Jacob Lew sent a letter to key members of Congress calling for the nation to embrace a “new sense of economic patriotism” and stop supporting corporations that are moving their tax home out of the U.S. to reduce their corporate income tax burdens by taking […]