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Effect Of The Financial Reform Bill On Alternative Investment Firms
Both in terms of tax reform (yet to be determined) and financial markets reform, alternative investment firms will face a new set of standards that will have a major impact on the firms, their principals and the investors in such funds. Hedge funds and private equity funds will be impacted by the...
Read MoreSeparation Pay Arrangements Under Section 409A
Almost six years have passed since the nonqualified deferred compensation plan rules were enacted by the American Jobs Creation Act of 2004. The Act created new section 409A under the Internal Revenue Code of 1986, as amended. Section 409A mandates specific requirements for nonqualified deferred...
Read MoreThe Deductibility Of Legal Expenses On Individual Tax Returns
The Internal Revenue Code allows for the deduction of some legal fees on Schedules A, C or E, while disallowing others. Still other legal fees are capitalized on Schedule D. The determination of which fees are either deductible or able to be capitalized is determined by the origin of the claim...
Read MoreCarried Interest And The Regulatory Landscape For Private Equity And Hedge Funds
Despite the predominance of healthcare reform in the current legislative activities, it is likely that the Obama administration will rekindle the attention on various tax changes once the smoke clears. One such area that received a great deal of attention several months ago involves the treatment...
Read MoreMadoff Losses - What To Do Next?
Certainly one of the most prominent occurrences of the recent economic crisis was the unraveling of the Madoff Ponzi scheme.As a consequence, thousands of victims of Bernie Madoff's $65 billion scam, and other similarly uncovered Ponzi schemes, have been able to claim "theft losses"...
Read MoreTests For Statutory Residency Versus Domicile In New York State And City
One of the most contested areas of state and local tax law are the concepts of statutory residency and domicile. In the metropolitan area, the issue arises in particular when a taxpayer may live in New Jersey but also maintain a residence in New York City. This is a particularly sensitive area if...
Read MoreFBAR Principles For A Fund Principal - Follow Up To FBAR Controversies
Foreign Bank and Financial Account ("FBAR") reporting, historically and currently driven by the Bank Secretary Act ("BSA"), as of late captured the interest of the IRS, which now administers FBAR compliance. This teaming up has created a number of definitional and...
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