Federal Tax

Hedge Funds (Portfolio 736)

  • The Portfolio, Hedge Funds, addresses the full range of U.S. tax issues that typically arise in the representation of hedge funds.

Description

Bloomberg Tax Portfolio, Hedge Funds, No. 736, addresses the full range of U.S. tax issues that typically arise in the representation of hedge funds. The purpose of this Portfolio is to provide a source of guidance to tax practitioners who regularly advise hedge funds, their Portfolio managers and their investors. It also includes descriptions of basic fund prototypes, the relevant regulatory environment, alternative fund structures, and common economic terms and variations thereon.

Table of Contents

I. Introduction
II. Fund Prototypes
III. The Basic Economic Deal
IV. Achieving Pass-Through Treatment for the Fund and Its Affiliates
V. Profit & Loss Allocations
VI. Special Tax Issues for the General Partner and Its Members
VII. Special Tax Issues for Foreign and Tax-Exempt Investors
VIII. Special Tax Issues for U.S. Individuals
IX. Key Hedge Fund Elections
X. Reporting of Transactions between Fund and Investors
XI. Portfolio Investments by the Fund: Recurring U.S. Tax Issues
XII. Investing in Hedge Fund Derivatives
XIII. Tax Shelter Reporting and List Keeping

needham-andrew-2015
Andrew Needham
Partner
Cravath Swaine & Moore LLP
Christian Brause
Christian Brause
Partner
Sidley Austin LLP
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