The change in taxation for Italian mutual funds establishes a level playing field among European products but introduces complexities in making a choice between mutual funds and pension funds (still taxed with maturity method), suggesting the necessity of a similar reform for pension funds taxation.

Lot layering may help hedge funds improve the alignment between tax outcomes and the economic experience of their investors. Although lot layering is considered by most tax experts to be the most precise method of partnership allocations, this commonly understood precision is reduced upon...

Controversy rages about how to tax carried interest. One view sees carry as compensation that should be taxed like other labor income. Another sees carry as a reward for financial risk-taking that should be taxed like capital income. A third sees carry as creating a costly tax arbitrage. In this...

Questions have been raised regarding the role of low-tax offshore jurisdictions in the global financial crisis, based largely on evidence that many problematic asset-backed securities were issued from or listed in the Cayman Islands, Jersey, Ireland, and other ‘offshore' sites. However, there...

The article discusses the U.S. federal income tax characterization of equity-flavored debt instruments issued by banks in compliance with bank regulatory rules adopted after the financial crisis of the late 2000's.Banks and other financial institutions must issue financial instruments that...

The Internal Revenue Service (“Service”) recently issued Revenue Procedure 2014-32. The Procedure announced a penalty-relief program (the “Pilot Program”) for those retirement plans that are not subject to the ERISA reporting requirements, but subject to the Code reporting requirements....

As a result of recent Treasury regulations, investment partnerships, such as hedge funds, might be required to allocate nonrecourse liabilities to their limited partners (LPs). This allocation of nonrecourse liabilities could result in recognition of capital gains by LPs when they contribute...