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International Tax Loopholes – The Playing Field Is Not Level
International Tax Loopholes – The Playing Field Is Not Level A recent Bloomberg article reported that the offshore cash hoard of U.S. multinational companies had risen by $206 billion last...
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Net Capital Requirements for Broker-Dealers
There is one common requirement faced by every type of broker-dealer (“BD”), the concept of Regulatory Net Capital; however, depending upon the type of business the BD engages in, the...
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The Trader vs. Investor Hurdle Just Gets Higher
The Trader vs. Investor Hurdle Just Gets Higher A few months back I wrote about the Nelson case, a Tax Court case dealing with a U.S. individual who claimed she...
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Deferral of Offshore Fund Performance Fees – New Developments
Deferral of Offshore Fund Performance Fees – New Developments The IRS has recently issued a ruling confirming that offshore funds can, in certain circumstances, defer incentive fees payable to U.S....
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Whistleblower Program
Whistleblower Program As part of a massive overhaul of the regulations governing our country’s financial system, Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) in July...
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Pharmaceutical Companies Continue to Plan Corporate Inversions Despite Government Protests
In late July, Treasury Secretary Jacob Lew sent a letter to key members of Congress calling for the nation to embrace a “new sense of economic patriotism” and stop supporting...
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The Whimsical World of Asset Management – Alternative Investment Jargon Defined
The Whimsical World of Asset Management – Alternative Investment Jargon Defined As with any niche or industry, the alternative investment industry has its own terminology. In fact, it would be...
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Attacking Carried Interest Through The Back Door
Attacking Carried Interest Through The Back Door Last week the United States Court of Appeals for the First Circuit handed down an opinion in favor of the Teamsters Union in...
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THINK “THE OPPOSITE” ABOUT FUNDING THE FEDERAL GOVERNMENT
THINK “THE OPPOSITE” ABOUT FUNDING THE FEDERAL GOVERNMENT Until the Mexico Olympics of 1968, high jumpers faced the bar, and the record stood at 5′ 8″. Dick Fosbury turned his...
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SEC’s NEW FORM PF
SEC’s NEW FORM PF In October 2011, the Securities and Exchange Commission (“SEC”) adopted Rule 204(b)-1 under the Investment Advisers Act of 1940 to require registered investment advisers (“RIAs”) that...