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Disclaimer
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Log in / Register. The views expressed on fund-taxation.com. Are solely those of the authors and do not represent the views and opinions of the authors’ organizations or employers. The discussions on this website are general in nature and do not, and are not intended to, constitute legal advice or legal opinions. Therefore, the information presented on fund-taxation.com. This website may contain links to external websites that are not affiliated with fund-taxation.com. National Venture Capital Association.
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Legislative Actions
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Log in / Register. The PATH Act of 2015 makes the 100% QSBS gain exclusion permanent. December 22, 2015 read more. Repeal of TEFRA and Electing Large Partnership Rules. November 04, 2015 read more. February 01, 2013 read more. Beware of the PTP Rules: Who Ends up Liable if a Secondary Transfer Triggers Section 7704? April 30, 2012 read more. Carried Interest Proposal Blocked in the Senate Yet Again. October 12, 2011 read more. Proposals to Tax Carried Interest at Ordinary Rates are Back. Congress Extends...
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hedge fund and private equity fund tax bibliography
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Log in / Register. Adele M. Karig,. US Taxation of Tax-Exempt and Foreign Investors in U.S. Private Investment Funds. Practising Law Institute (2008). Amanda N. Persaud, Adrienne Atkinson,. Private Equity Funds: Legal Analysis of Structural, ERISA, Securities and Other Regulatory Issues. Amy S Elliott and Lee A. Sheppard,. Private Equity Fund Is in a Trade or Business, First Circuit Holds. Portfolio 735-2nd: Private Equity Funds. Portfolio 736-1st: Hedge Funds. Tax Analysts Doc 2002-12742 (2002). The Tax...
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“Investor Control” doctrine shuts down investment manager’s private placement insurance planning
http://fund-taxation.com/articles/cases/investor-control-doctrine-shuts-down-investment-managers-private-placement-insurance-planning
Log in / Register. Investor Control doctrine shuts down investment manager’s private placement insurance planning. July 01, 2015. Webber v. Comm’r. The opinion can be found here. You must be logged in. To post a comment. Tags: investor control doctrine. Alternative Investment Management Association. Association of Institutional Investors. Institutional Limited Partners Association. National Venture Capital Association. Securities Industry and Financial Markets Association. Revived focus on monitoring fees.
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Administrative Actions
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Log in / Register. Temporary Regs Shut Down Partner-Employee Planning. May 04, 2016 read more. FAA 20161101F A tax equity deal gone wrong. March 18, 2016 read more. Fee Waiver Hearing Set for February 26th. January 27, 2016 read more. In FFA 20154703F Chief Counsel blesses the taxpayer’s hedging transactions. December 03, 2015 read more. TD 9734: Treasury Releases Final and Temporary Section 871(m) Regulations. September 17, 2015 read more. July 24, 2015 read more. July 10, 2015 read more. CCA 201501013 ...
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Tax Provisions In Subscription Agreements
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Log in / Register. Tax Provisions In Subscription Agreements. April 08, 2015. This document contains examples and analysis of the typical tax provisions you will see in subscription agreements. A lot of these provisions are self-explanatory. They are definitively pro-GP and usually exculpate the GP, or obligate the LP to do or represent something. The document is relatively short at 25 pages, which is a reflection of the fact that this type of document is relatively light on tax. FATCA Reps and Covenants.
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Documents
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Log in / Register. Below you will find a list of our current documents. We believe that these documents represent the most essential elements of the investment fund and private M&A deal-flow. As newer drafting approaches, substantive law changes, or other material changes come up, we plan on updating these documents with additional drafting alternatives and content. If you have any specific questions about a document please do not hesitate to contact us at staff@fund-taxation.com. Go to mobile version.
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