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Taxation of US Investment Partnerships and Hedge Funds Accounting Policies Tax Allocations and Performance Presentation Wiley Professional Advisory Services 1st Edition by Vasavada ISBN 9780470642566 0470642564

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Taxation of US Investment Partnerships and Hedge Funds Accounting Policies Tax Allocations and Performance Presentation Wiley Professional Advisory Services 1st Edition N. Vasavada Digital Instant Download

Author(s): N. Vasavada
ISBN(s): 9780470642566, 0470642564
Edition: 1
File Details: PDF, 1.47 MB
Year: 2010
Language: english
SKU: EB-1777864 Category: Tag:

Taxation of US Investment Partnerships and Hedge Funds Accounting Policies Tax Allocations and Performance Presentation Wiley Professional Advisory Services 1st Edition by N. Vasavada- Ebook PDF Instant Download/Delivery: 9780470642566, 0470642564
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Product details: 

ISBN 10: 0470642564

ISBN 13: 9780470642566

Author: Navendu P. Vasavada 
A new, lucid approach to the formulation of accounting policies for tax reporting

Unraveling 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 US investment partnerships and hedge funds

Providing tremendous understanding to a complex topic, Taxation of US Investment Partnerships and Hedge Funds is guaranteed to demystify the inner workings of the formulation of accounting policies for tax reporting

Table of contents: 

Chapter 1. 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

  • Fund-of-Funds

  • Incentives of the Hedge Fund Manager and Investors

  • Valuation of a Hedge Fund Management Company

  • Economies of Scale in Hedge Funds

Chapter 2. The Structure of Hedge Funds

  • Organizing a Typical Offshore Hedge Fund

  • Master-Feeder Structuring of Onshore/Offshore Arms

  • U.S. Withholding Agent for U.S. Withholding Taxes on Foreign Investors

Chapter 3. 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

  • Net Asset Value (NAV) per Share

  • Black-Scholes Formula Valuation of Performance Fees

Chapter 4. Hedge Fund Accounting and Tax Filing

  • Partnership Accounting for U.S. Funds

  • IRS Tax Return Filings

  • Financial Statements for Hedge Funds and Venture Funds

  • Interim Valuation

  • Books of Account and Financial Statements

  • Audit of an Offshore Fund

  • Audit of a U.S. Fund

  • Capital Account Audit for Both Offshore and U.S. Funds

Chapter 5. Partner Tax Allocations in U.S. Partnerships

  • U.S. Tax Allocation Rules

  • Tax Components of Investment Partnership Income

  • Fixed Fees: GP and LP Allocations

  • Allocation Formula for Other Income Components

  • Tax Basis of Partner’s Investment

  • Accountants’ Terminology

  • Allocation of Realized & Unrealized Income

  • Layering Method

  • Tax Allocation of Interest, Dividends, Investment Expense, Foreign Tax

  • Guaranteed Payments to the GP

  • Tax Consequences of Shorting

  • Distributions from Partnerships

Chapter 6. Tax Allocations of Realized Gains by Layering

  • Layering Method for Capital Gains

  • Ambiguity #1

  • Work-Around for Ambiguity #2

Chapter 7. Partial and Full Netting Methods

  • Methods of Aggregation / Netting

  • Partial Netting

  • Full Netting

  • Measuring Book-Tax Disparity

  • Optimization Problem under Full Netting

  • Optimization Problem under Partial Netting

  • Solving the Convex Optimization Problem

Chapter 8. Comparative Tax Consequences of Layering and Netting

  • Comparing Layering, Full Netting, and Partial Netting

  • Layering Examples (Earlier Tax Payment)

  • Full Netting Examples (Tax Postponement)

Chapter 9. Tax Efficiency of Hedge Funds

  • Tax Efficiency for Offshore Hedge Funds

  • Tax Preference Ordering for U.S. Investors

  • Attractive vs. Less Attractive Tax Items

  • Special Preference: Exchange-Traded Futures

  • Ambiguities in Tax Preferences

  • Tax Efficiency Steps

  • Structure for Tax-Exempt Entities to Recover Foreign Taxes

Chapter 10. Hedge Fund Performance and Risk Presentation

  • CFA Institute GIPS Verification

  • Hedge Fund Return Calculation

  • Historical Risk & Return Review Using GIPS

Chapter 11. Mutual Funds and Venture Funds Compared to Hedge Funds

  • Tax Filing Complexity

  • Comparison with Mutual Fund Tax Allocations

  • U.S. Venture Partnerships

Chapter 12. Epilogue

  • Economic Accounting for U.S. and Offshore Funds

  • Complexity of U.S. Partnership Tax Filing

  • Partner Allocations as Core of Tax Accounting

  • Layering vs. Netting

  • Example of 100-Partner Allocation

  • Tilting Allocations per Tax Preferences

  • Automated Tax Allocation

  • The End of the Layering Era

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