Category: Hedge Fund

Australia targets offshore banking units

Under pressure from international organisations, the Australian government has flagged that it is getting ready to reform the concessionally-taxed offshore banking unit (OBU) regime, a move that will hit big banks and hedge funds. The Organisation for Economic Co-operation and Development’s (OECD) forum on harmful tax practices has raised concerns… – Continue reading

Bitcoin Hedge Funds Caught in IRS Crypto Tax Crosshairs Amidst Unclear Regulations

Hedge Funds Are Struggling to Correctly Tax Crypto Holdings Amidst Unclear Regulations According to US law, bitcoin and other cryptocurrencies are taxed like property – similar to real estate. Amidst unclear regulations, however, hedge funds are struggling to correctly pay their taxes, which is a problem because the IRS just… – Continue reading

Art of the deal: Trump, Dems look for common ground to close tax loopholes

Venture capitalists, investors left unfazed Both President Trump and Capitol Hill Democrats head into negotiations over tax reform vowing to put the squeeze on hedge fund managers by closing the carried interest tax loophole — a point of agreement that held out promise for becoming a foundation for a once-in-a-generation… – Continue reading

OECD’s MLI: will tax treaty benefits apply to private equity investors?

The OECD recently released a public discussion draft entitled the “BEPS Action 6 Discussion Draft on non-CIV examples” to clarify when investors like private equity funds, real estate funds and hedge funds should be entitled to tax treaty benefits. The release of the 2017 Discussion Draft is timely, given that… – Continue reading

Senators tell new US treasury secretary nominee to eliminate Cayman Islands and other tax havens

WASHINGTON, USA — Members of the United States Senate, questioning the new Trump administration nominee for Treasury Secretary on Thursday, asked Steve Mnuchin how he intends to close down Caribbean tax havens, specifically naming the Cayman Islands. The Senate panel demanded details on how the new secretary expects to close… – Continue reading

UN expert urges next UN chief to crack down on Malta and other ‘tax havens’

A United Nations human rights expert has urged the next UN secretary-general to make the elimination of tax havens a priority to ensure that corporations, billionaires and ‘kleptocrats’ pay their fair share of taxes. Speaking on Friday, American law professor Alfred de Zayas also urged Antonio Guterres, who will succeed… – Continue reading

U.S. tax hunt overseas causes global headaches

There is little that can be done about FATCA and the change has to come from within the U.S. Death and taxes, life’s two certainties according to Keynes, sometimes have a causal relationship. One dies and some taxes are often associated with that event. Alternatively, one encounters so much regulation… – Continue reading

IRS Proposes New QI Agreement for Foreign Banks to Comply with FATCA

The Internal Revenue Service has released new guidance on how foreign financial institutions can enter into a Qualified Intermediary agreement with the U.S. under the Foreign Account Tax Compliance Act, or FATCA. Notice 2016-42, released earlier this month, outlines the proposed QI agreement, which revises and updates the current agreement… – Continue reading

Practically Untouchable: Going Offshore Still Has Benefits

THE RECENT LEAK of millions of documents from Panamanian law firm Mossack Fonseca served as a reminder of what wealthy Americans should already know: Hiding assets offshore can be risky and hiding them from Uncle Sam is a crime. Yet law-abiding folks continue to stash money offshore for reasons that… – Continue reading

India-Mauritius tax treaty: An end and a new beginning

Recent news of India and Mauritius signing a Protocol to amend their 33 year old tax treaty caused seismic changes in the tax world. Though not completely unanticipated, the change is significant for foreign investors to go back to the drawing board and reassess their structures. The tax treaty between… – Continue reading

LMA Updates its Standard Terms and Conditions to Incorporate FATCA Provisions

On 20 April 2016, the Loan Market Association (“LMA”) updated its Standard Terms and Conditions for Par and Distressed Trade Transactions (Bank Debt/Claims) (“Standard Terms”) to include language that covers FATCA (as defined below) tax withholding on certain payments of US source FDAP income and, potentially, sale proceeds (as described… – Continue reading

Finomial Delivers Comprehensive Solution For OECD CRS

Finomial Corporation today announced the launch of a comprehensive and automated online investor services and tax reporting platform. This software enables financial institutions to meet the compliance requirements for the Common Reporting Standard (CRS) mandated by the OECD (Organization for Economic Cooperation and Development). These new tax regulations require that… – Continue reading

PE Panorama: Is the UK Budget 2016 really PE-friendly?

Private equity (PE) populism looks to be in the news again – though in a context that’s unlikely to win too many votes for the instigators. This time it’s the UK, and Chancellor George Osborne’s latest budget. The UK Budget 2016 (the Budget) includes a significant reduction in the UK… – Continue reading

Are You Keeping Secrets from Uncle Sam Overseas?

If you think Uncle Sam has too many other problems to worry about what assets you may be hiding overseas, think again. “Governments are catching up to the fact that there is now a global economy and are requiring increasing reporting to ensure they collect ‘their fair share’ of tax… – Continue reading

Untangling the Gordian Knot

Regulatory and investor pressure have drastically altered the hedge fund industry in recent years. With managers increasingly looking for fund administrators to provide more middle-office and value-added services, whilst at the same time squeezing them on fees, the situation has become a Gordian Knot. Administrators must find ways to remain… – Continue reading

On tax avoidance

The only thing worse than paying taxes is the idea that other people avoid paying their fair share of them. On the subject of tax avoidance by other people, I can think of at least three principal feelings. As the kids say, I feel all the feelings. Outright tax fraud… – Continue reading

Paulson Reinsurer Winds Down After Slump, Tax Criticism

Billionaire John Paulson’s New York hedge fund firm has shut an operation in Bermuda that had been targeted by a Democratic lawmaker as a tax shelter. Paulson’s venture, a reinsurer named PacRe Ltd., has stopped writing new coverage, and its insurance policies have expired, according to two people familiar with… – Continue reading