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Proskauer Rose LLP

Proskauer’s Hedge Start: Key Tax Issues

Proskauer Rose LLP on

Different hedge fund investors have different tax concerns that must be taken into account when structuring a hedge fund and its portfolio investments. Hedge fund investors generally fall into three categories:...more

Eversheds Sutherland (US) LLP

Deemed participation better than no participation? Proposed regulations expand tax-free treatment to section 956 inclusions of...

Eversheds Sutherland (US) LLP on

On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of the Internal Revenue Code of...more

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