Summary
The Treasury Department recently issued a variety of proposed, temporary and final regulations that may impact funds and their managers. These new regulations span issues such as valuation with respect to mark-to-market tax reporting, foreign withholding within the partnership context and transfer of partnership interests for services performed.
Safe Harbor for Valuation Under Mark-to-Market ElectionSee the full content of this document
Extract
A Consideration of New Treasury Regulations
In an attempt to alleviate some administrative burden for certain taxpayers, the Internal Revenue Service has issued proposed regulations that allow for a safe harbor with respect to security and commodity valuation in the context of an Internal Revenue Code (IRC) Section 475 mark-to-market election. Due to a myriad of factors such as short-term trading strategy and administrative issues including tax shelter reporting, some hedge fund managers that qualify as traders have elected under IRC Section 475 to mark- to-market their respectiv...
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