transcript   Transcript

The Unrelated Business Income Tax: Issues for Hedge Fund Managers

Recorded on: Jan. 17, 2018
Running Time: 01:00:24

Full Transcript:



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Taken from the Web Program Taxation of Financial Products and Transactions 2018 Recorded January 2018 in New York

The Unrelated Business Income Tax: Issues for Hedge Fund Managers [01:00:24]

  • Refresher on basic compliance issues
  • Planning around the debt-financed property rules
  • Working with blockers: guarantees, pledges, and third party debt
  • Use of insurance dedicated funds

Mark P. Howe, Stuart E. Leblang, Amanda H. Nussbaum, Elinor C. Ramey

The purchase price of this Web Program segment includes the following article from the Course Handbook available online:

  • Taxation of United States Tax-Exempt Entities’ Offshore Hedge Fund Investments: Application of the Section 514 Debt-Financed Rules to Leveraged Hedge Funds and Derivatives and the Case for Equalization
    Summer A. Lepree
  • The Unrelated Business Income Tax: Issues for Hedge Fund Managers (PowerPoint slides)
    Amanda H. Nussbaum
Presentation Material
  • The Unrelated Business Income Tax: Issues for Hedge Fund Managers
    Mark P. Howe, Stuart E. Leblang, Amanda H. Nussbaum
    (s)
    Mark P Howe ~ Cadwalader Wickersham & Taft LLP
    Stuart E Leblang ~ Akin Gump Strauss Hauer & Feld LLP
    Amanda H Nussbaum ~ Proskauer Rose LLP
    Elinor C Ramey ~ Attorney Advisor, Office of Tax Policy, U.S. Department of the Treasury
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