Insights

Fund managers may be required to file Treasury International Capital (“TIC”) Form SHL, Report of Foreign-Residents’ Holdings of U.S. Securities, Including Selected Money Market Instruments (SHL (2024)) by August 30, 2024, based on the fair value (determined as of June 28, 2024) of certain U.S. securities issued to foreign persons. This client alert focuses on…

Client Alerts | August 7, 2024 | Hedge Funds | Private Equity Funds

The U.S. Department of Labor (the “DOL”) recently amended the qualified professional asset manager (“QPAM”) exemption. The QPAM exemption is commonly relied on by fund managers that manage “plan assets” either through separately managed accounts or funds that exceed the 25% benefit plan investor test. If a manager is a QPAM, then certain transactions that…

Client Alerts | August 5, 2024 | Hedge Funds | Private Equity Funds

Each year, we send a newsletter to our clients and friends regarding Section 475(f) mark-to-market elections. A 475(f) election must be made by partnerships before March 15th of the year in which the election is to be effective and can be overlooked while people are focused on preparing prior year tax returns and K-1 estimates.…

Client Alerts | February 28, 2024 | Hedge Funds | High Net Worth Individual Planning | Private Equity Funds

This newsletter briefly highlights certain tax issues and planning that fund managers and high-net-worth individuals should consider (or reconsider) before and shortly after the end of 2023. There does not appear to be any proposed tax legislation that is expected to be enacted in the near-term, but that is always subject to change. There have…

Client Alerts | December 21, 2023 | High Net Worth Individual Planning | Hedge Funds | Private Equity Funds

New York Pass-Through Entity Tax (“PTET”) Due Date for Elections The due date to make elections to pay the New York State and New York City PTET for 2023 is March 15, 2023. March 15, 2023, is also the due date to elect to pay the New York City PTET for 2022, but such election…

Client Alerts | March 9, 2023 | Hedge Funds | Private Equity Funds

2022 New York State Pass-Through Entity Election Deadline The original deadline to make the New York State pass-through entity tax (“NYS PTET”) election for 2022 was March 15, 2022, but in May was extended to September 15, 2022. (Please click here for our May 2022 alert on the extension of the NYS PTET deadline.) An…

Client Alerts | September 1, 2022 | Hedge Funds | Private Equity Funds

The stock and crypto markets are both significantly down from the beginning of 2022. Funds and other investors may have considerable realized and unrealized losses. Tax planning may help soften the economic impact. In this alert, we focus on tax planning for funds and individuals. The type of tax planning that may be available depends…

Client Alerts | June 27, 2022 | Hedge Funds | Private Equity Funds

NYS PTET Election Deadline for 2022 Extended to September 15, 2022 On May 6, 2022, Governor Hochul signed into law a bill that extends the New York State Pass-Through Entity Tax (the “NYS PTET”) election deadline for the 2022 tax year to September 15, 2022. Previously, the election deadline for 2022 was March 15, 2022.…

Client Alerts | May 17, 2022 | Hedge Funds | Private Equity Funds

On April 9, 2022, Governor Hochul signed legislation which creates an elective NYC Pass-Through Entity Tax (the “NYC PTET”) that is very similar to the New York State Pass-Through Entity Tax (the “NYS PTET”). The NYC PTET allows certain partnerships and S corporations to elect to pay an entity level tax at a rate of…

Client Alerts | April 20, 2022 | Hedge Funds | Private Equity Funds

This newsletter serves as a reminder regarding several deadlines and action items regarding the New York State Pass-Through Entity Tax (the “NYS PTET”). March 15, 2022, Deadline The deadline to elect into the NYS PTET for 2022 is March 15, 2022. The election is made on an annual basis, so an election for 2022 will…

Client Alerts | February 17, 2022 | Hedge Funds | Private Equity Funds