Insights

Fund managers may be required to file Treasury International Capital (“TIC”) Form SHC, Report of U.S. Ownership of Foreign Securities, Including Selected Money Market Instruments (“Form SHC”), for 2021 by March 4, 2022, based on the fair value of foreign assets owned by U.S. persons determined as of December 31, 2021. For 2021 and other benchmark…

Client Alerts | February 11, 2022 | Hedge Funds | Private Equity Funds

Each year, we send an annual newsletter to our clients and friends regarding Section 475(f) mark-to-market elections. A 475(f) election must be made by partnerships early in the year (by March 15, 2022, for 2022) and can be overlooked while people are focused on preparing tax returns and K-1 estimates for the prior year. A…

Client Alerts | February 8, 2022 | Hedge Funds

This tax alert briefly highlights certain tax issues and planning that hedge and private equity fund managers and high-net-worth individuals should consider (or reconsider) now that we are in the new year. Our 2021 year-end tax alert highlighted many items to consider and potential tax moves to take before year-end and highlighted proposed tax changes.…

Client Alerts | January 10, 2022 | Hedge Funds | High Net Worth Individual Planning | Private Equity Funds

This annual client alert briefly highlights certain tax issues and planning that hedge fund managers and high-net-worth individuals should consider (or reconsider) before the end of 2021. Although year-end tax planning is always important, the potential increase in tax rates in 2022 and other potential tax changes make it even more important this year-end. The…

Client Alerts | December 7, 2021 | High Net Worth Individual Planning | Hedge Funds | Private Equity Funds

Tax Planning for Fund Managers and Other High-Net-Worth Individuals Earlier this year, New York State enacted a new elective pass-through entity tax (the “PTET”). The PTET generally allows individuals who are members of pass-through entities to effectively receive a federal deduction for New York State income taxes that they would otherwise not be able to deduct. On…

Client Alerts | September 1, 2021 | Hedge Funds | Private Equity Funds

On June 17, 2021, the U.S. Securities and Exchange Commission (the “SEC”) issued an order (the “Order”1) increasing the dollar amount tests in order to qualify as a “qualified client” in Rule 205-3 (the “Rule”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). As described below, these changes will be effective…

Client Alerts | August 2, 2021 | Investment Management | Hedge Funds | Private Equity Funds