Hedge Funds

Hedge Funds

We specialize in independent, objective and practical planning advice for successful hedge funds, their general partners and portfolio companies.

While hedge fund ownership can provide significant opportunities through hedge, venture and buy-out investments, the complexity created due to cash flow, valuation, distribution, diversification and transfers can result in significant tax planning needs.

We can help. Our professionals have extensive experience assisting hedge funds and their partners, and are fluent with multiple aspects of hedge fund investing. Our comprehensive, practical approach focuses on the funds and their partners, assisting them to plan for and make decisions that will help them achieve their goals on a tax-efficient basis. We offer an organized, experience-based approach.

We advise several of the largest hedge funds in the United States and continues to address the complex issues facing the industry, providing the following expertise:

  • Strategies for optimal fund structure

  • Preparation of Form 1065s and state and local tax returns, including calculation of financial statement-to-tax differences

  • Preparation of Schedule K-1s, reporting to meet U.S. filing requirements and U.S. tax reporting obligations

  • Preparation of passive foreign investment company (PFIC) statements, including consideration of the excess distribution regime, mark-to-market regime, and the qualified electing fund (QEF) regime

  • Preparation of interim tax information

  • Planning/analysis of fund structure with regard to unrelated business taxable income (UBTI) for tax-exempt entities, effectively connected income (ECI) for foreign investors and other special investor issues

  • Preparation of tax documentation to obtain withholding tax refund in accordance with international tax treaties

  • Tracking contributed property and mandatory built-in gain or loss basis adjustment calculations

We also address the needs of hedge fund partners in bringing the following services to its individual clients:

  • Strategies for profits interest ownership including analysis of prospective legislation

  • Diversification of wealth concentration

  • Post-diversification consulting

  • Qualified small business stock (QSBS) considerations

Contact Global Tax Advisers to learn more!