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4 results on '"Hedge funds -- Laws, regulations and rules -- Taxation"'

1. Chapter 15. Private Funds.

Author

Mowbray, Nicholas C., Kramer, Andrea (Andie) S., Behar, Rachel, Knipp, Laura, and Eichenstein, Samuel

Subjects
Limited liability companies -- Laws, regulations and rules -- Taxation, Limited partnership -- Laws, regulations and rules -- Taxation, Tax exemption -- Laws, regulations and rules, Private equity -- Laws, regulations and rules -- Taxation, Corporations -- Laws, regulations and rules -- Taxation, Hedge funds -- Laws, regulations and rules -- Taxation, Government regulation, Foreign Investment in Real Property Tax Act of 1980, Tax Cuts and Jobs Act of 2017, Investment Company Act of 1940 (15 U.S.C. 3(c)(7)), Internal Revenue Code (I.R.C. 1061)
Abstract

[section]15.01 Overview Private funds (or "funds") are pooled investment vehicles managed by a sponsor with the purpose of making investments in accordance with the fund's investment objective. An investment manager [...]

Published
2023

2. The 21st century tontine lookalike: Tax aspects of stock protection funds.

Author

Boczar, Thomas and Leeds, Mark

Subjects
Recognized gain or loss (Taxation) -- Laws, regulations and rules -- Management, Hedge funds -- Laws, regulations and rules -- Taxation, Income tax -- Laws, regulations and rules -- Management, Government regulation, Company business management, Internal Revenue Code (I.R.C. 1259-1260)
Abstract

Tontine Trusts, initially devised in the 17th century Lorenzo de Tonti to help governments fund war efforts, are making a 21st century resurgence. (1) A tontine is an investment plan [...]

Published
2017

3. SCC Tax Decision: Derivative Contract That Neutralizes Risk Is A Hedge

Author

Watson, Gwen

Subjects
Hedge funds -- Laws, regulations and rules -- Taxation, Derivatives (Financial instruments) -- Taxation -- Laws, regulations and rules, Government regulation, Business, international
Abstract

In MacDonald v. Canada (MacDonald)1, the majority of the Supreme Court of Canada (SCC) held that a derivative contract entered into by the taxpayer constituted a 'hedge' of the taxpayer's [...]

Published
2020

4. IRS Publishes Proposed Regulations For Hedge Fund Reinsurance Arrangements

Author

Ma, Sarah

Subjects
Insurance companies -- Investments -- Taxation -- Laws, regulations and rules, Hedge funds -- Laws, regulations and rules -- Taxation, Insurance law -- Interpretation and construction, Insurance policies -- Laws, regulations and rules, Government regulation, Company investment, Business, international
Abstract

In April 24's Federal Register, the IRS released proposed regulations (REG-108214-15) to restrict when a foreign insurance company's income can be excluded as passive income by giving a more strict [...]

Published
2015

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