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Taxation of U. S. Investment Partnerships and Hedge Funds Accounting Policies, Tax Allocations, and Performance Presentation

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ISBN-10: 0470605758

ISBN-13: 9780470605752

Edition: 2010

Authors: Navendu P. Vasavada

List price: $155.95
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A new, lucid approach to the formulation of accounting policies for tax reportingUnraveling the layers of complexity surrounding the formulation of accounting policies for tax reporting, Taxation of US Investment Partnerships and Hedge Funds: Accounting Policies, Tax Allocations and Performance Presentation enables your corporation to implement sound up-front accounting and tax policies in order to reduce the overall cost of CFO and legal functions within a U.S. Investment partnership. Understand the pitfalls and optimize across legitimate policies that are consistent with the IRS regulations Presents a clear roadmap for accounting, tax policies, tax filing and performance presentation for…    
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Book details

List price: $155.95
Copyright year: 2010
Publisher: John Wiley & Sons, Limited
Publication date: 7/8/2010
Binding: Hardcover
Pages: 304
Size: 6.30" wide x 9.30" long x 1.00" tall
Weight: 1.100
Language: English

The Arcane World of Hedge Funds and Investment Partnerships
What Is a "Hedge Fund"?
U.S. Venture Partnerships
Types of U.S. Hedge Fund Entities and the U.S. Tax Code
Organizing a Typical U.S. Hedge Fund
Investor Clienteles in Hedge Funds
Foreign Investors in a U.S. Hedge Fund
Offshore Funds
U.S. Investors in Offshore Funds
U.S. Investors in Swiss Bank Accounts
U.S. Investors in Madoff-Like Managed U.S. Trading Accounts
Size of the Global Hedge Fund Industry
Incentives of the Hedge Fund Manager and Investors
Valuation of a Hedge Fund Management Company
Economies of Scale in Hedge Funds
The Structure of Hedge Funds
Organizing a Typical Offshore Hedge Fund
Master-Feeder Structuring of Onshore/Offshore Arms: Organizing a Hedge Fund for Clienteles
U.S. Withholding Agent for U.S. Withholding Taxes on Foreign Investors
Hedge Fund Fees
Starting Point: The Partnership Agreement
Fund Valuation at Discrete Opening Time Points
Calculation of Fixed Fees
Calculation of Performance Fees
Claw-Back Provision: Performance Fee Returned to Limited Partners
Representation of a Fund's Net Asset Value (NAV) per share
Black-Scholes Formula Valuation of Performance Fees
Hedge Fund Accounting and Tax Filing
Partnership Accounting for U.S. Funds
IRS Tax Return Filings for U.S. Hedge Funds
Financial Statements for Hedge Funds and Venture Funds
Interim Valuation: The Core of a Hedge Fund's Accounting Operation
Books of Account and Financial Statements for Hedge Funds
Audit of an Offshore Fund
Audit of a U.S. Fund
Capital Account Audit for Both Offshore and U.S. Funds
Partner Tax Allocations in U.S. Partnerships
U.S. Tax Allocation Rules Governing U.S. Partnerships
Tax Components of U.S. Investment Partnership Income
Fixed Fees: Income to the General Partner and Expense to the Limited Partners
Generalizing the Allocation Formula to Other Components of Income
Tax Basis of Partner's Investment in a U.S. Partnership
Accountants' Terminology
Tax Allocations of Realized and Unrealized Income to Partners
The Tax Allocation Method of Layering
Tax Allocation of Interest
Tax-Exempt Interest Income, Line 18a
Similar Calculation for Tax Allocation of Dividends, Investment Expense, Foreign Tax Paid
Tax Allocation of Fixed Fees Paid by Limited Partners
Tax Allocation of Guaranteed Payments (of Fixed Fees) to the General Partner
Reporting Subcomponents of Interest Income and Dividends
Tax Consequences of Shorting
Short Positions: Tax Treatment of Equity Dividends or Bond Coupons Claimed as Interest Expense
Distributions from Partnerships Owned
Tax Allocations of Realized Gains by Layering
Tax Allocation of Unrealized and Realized Capital Gains Using the Method of Layering
Ignoring Ambiguity #1 with Layering
Work-Around to Fix Ambiguity #2, The Fatal Flaw with Layering
Partial and Full Netting Methods
The Methods of Aggregation or Netting
Partial Netting
Full Netting
Measures of Book-Tax Disparity across Partners
Formulating the Problem for Optimal Partner Tax Allocations under Full Netting
Formulating the Problem for Optimal Partner Tax Allocations under Partial Netting
Solving the Convex Optimization Problem of Tax Allocation
Comparative Tax Consequences of Layering and Netting Methods
Which Is the Better Method for Allocation of Realized Gains: Layering, Full Netting, or Partial Netting?
Layering Examples Showing Earlier Tax Payment
Full Netting Examples Showing Tax Postponement
Tax Efficiency of Hedge Funds
Tax Efficiency Considerations for Offshore Hedge Funds
Tax Preference Ordering for U.S. Investors
More Attractive Tax Items to U.S. Investors
Less Attractive Tax Items to U.S. Investors
An Exception: Special Tax Preference for Gains from U.S. Exchange-Traded Futures Contracts
Ambiguities in Tax Preference
Tax Efficiency Steps for U.S. Hedge Funds
A Structure for Tax-Exempt U.S. Entities to Recover Foreign Taxes
Hedge Fund Performance and Risk Presentation
Performance Presentation: CFA Institute GIPS Verification
Calculation of Hedge Fund Returns for Performance Presentation
Facilitating Historical Risk and Return Review for Investors Using GIPS Guidelines
Mutual Funds and Venture Funds Compared to Hedge Funds
Tax Return Filing of U.S. Partnerships Is an Involved Task
Comparison with Tax Allocations Made by Mutual Funds
U.S. Venture Partnerships (Silicon Valley Venture Funds)
Economic Accounting Is a Common Denominator for U.S. and Offshore Funds
Tax Return Filing of U.S. Partnerships Is an Involved Task
Calculating Partner Allocations Is Most of a U.S. Partnership's Tax Accounting Effort
Layering and Netting Methodologies for Tax Allocation of Capital Gains
Example of Tax Allocation of Capital Gains by Full and Partial Netting in a 100-Partner Setting
Tilting Tax Allocations According to Tax Preferences
The Crown Jewel: Automated Tax Allocation of All Items of Income
The End of an Era of Layering
Excerpts of Key U.S. Statutes Discussed in Chapter 1 That Govern U.S. and Offshore Hedge Funds Venture Funds
Methodology and Implementation Example of Full Netting
Methodology and Implementation Example of Partial Netting
Nonabusive Tilting of Tax Allocations According to Tax Preferences
Eliminating Layering Entirely, by Allocating Dividends, Interest, Capital Gains, and Expenses in One Step