The ownership nationality of large US multinational companies plays an implicit but important role in the current debate over how such companies should be taxed. This paper identifies that role and investigates what is actually known about where these companies’ shareholders reside

Limited partnerships are attractive investment vehicles for investors because, as limited partners, investors cannot lose more than their invested capital despite the leverage of the partnership's portfolio. Consistent with this, the availability of tax losses to a limited partner is also more...

This Article explains how to create “survivor funds” — short-term investment funds that would pay more to those investors who live until the end of the fund's term than to those who die before then. For example, instead of just investing in a 10-year bond and dividing the proceeds among...

For several years, a debate has swirled around the taxation of hedge fund managers' compensation. Because it is structured as a type of partnership interest in the hedge fund, hedge fund managers may be eligible to pay taxes at lower capital gains rates on a large percentage of their income from...

The rich, it turns out, are different from the rest of us. The wealthy, for example, can assemble a diversified portfolio of securities, or can invest through hedge and private equity funds. When the rest of us invest, we do so largely through mutual funds. Nearly half of American households own...

The paper will first briefly discuss the tax implications of the ‘funds-specific' directives and will proceed to analyse the Parent-Subsidiary Directive (PSD), the Anti-Tax Avoidance Directive (ATAD), the Directive on Administrative Cooperation in Direct Taxation (i.e., ‘exchange of...

Looking at collective investment schemes from a financial law perspective seems to stand in harsh contrast to the OECD's perspective as expressed in the materials to BEPS Item 6. While financial lawyers emphasize the use of collective investment schemes – for manifold-financial relationships...

Mistakes occur in every profession, and attorneys practicing estate administration are not immune from this phenomenon. Funding marital trusts at the death of the first spouse engenders numerous opportunities for mistakes given the complex and technical nature of the tax law and the variety of...

The taxation of private equity managers' share of funds' profits — the twenty percent “carried interest” — received much attention in academic literature and popular discourse. Much has been said and written about the fact that fund managers' profits are taxed at preferred rates. But...