Sun, May 3, 2015
A A A
Welcome Guest
Free Trial RSS
Get FREE trial access to our award winning publications
Alternative Market Briefing

Partnership structure for hedge funds trips up IRS auditors

Tuesday, August 05, 2014

Bailey McCann, Opalesque New York:

A new report from the US General Accounting Office (GAO) shows that the partnership structure of hedge funds and private equity firms is tripping up IRS auditors. The report notes that partnerships typically have fewer IRS audits, and when they are audited the net change of reported income is so small, the GAO has asked if IRS auditors can effectively audit the structure.

"Internal Revenue Service (IRS) data show, from tax years 2002 to 2011, the number of large partnerships more than tripled. According to IRS officials, many large partnerships are hedge funds or other investment funds where the investors are legally considered partners. Many others are large because they are tiered and include investment funds as indirect partners somewhere in a tiered structure. According to IRS data, there were more than 10,000 large partnerships in 2011. A majority had more than 1,000 direct and indirect partners although hundreds had more than 100,000. A majority also had six or more tiers," the report explains noting that the regulator only audits 0.8% of partnerships compared to over 27% of corporations.

"These minimal audit results may be due to challenges hindering IRS's ability to effectively audit large partnerships. Challenges included administrative tasks required by the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and the complexity of large partnership structures due to tiering and the large number of partners. For......................

To view our full article Click here

Today's Exclusives Today's Other Voices More Exclusives
Previous Opalesque Exclusives                                  
More Other Voices
Previous Other Voices                                               
Access Alternative Market Briefing


  • Top Forwarded
  • Top Tracked
  • Top Searched
  1. U.S. does not want hedge funds to invest in offshore re-insurers for tax purposes[more]

    Komfie Manalo, Opalesque Asia: The U.S. Treasury Department on Thursday introduced a new rule aimed at limiting hedge funds’ ability to reduce their tax bills by investing in insurance companies in offshore tax havens. As a general rule, the U.S. tax laws does not allow hedge funds to use off

  2. Swiss group Pictet releases first public annual and financial reports[more]

    Benedicte Gravrand, Opalesque Geneva: Pictet Group, a Swiss private bank, has just released its first public annual report and financial report since it opened for business in Geneva in 1805. I

  3. Opalesque Exclusive: Carne establishes non-EU ManCo in Jersey[more]

    Benedicte Gravrand, Opalesque Geneva: For those managers who will not domicile their fund in the European Union (EU) and yet want to distribute it in the EU – especially the UK –, going under the wing of an AIFMD-compliant ManCo on the Channel Islands could be one of the ways to do it. Ch

  4. SEC charges funds of hedge funds Alpha Titans, executives, and auditor for improper expense allocations[more]

    Update: Please note the important updated information at the end of the article.The Securities and Exchange Commission today announced charges against a Santa Barbara, Calif.-based hedge fund advisory firm and two executives involved in improper allocations of fund assets to pay undisclose

  5. Opalesque TV: Aequam Capital: Asset management industry will be mainly quantitative going forward[more]

    Benedicte Gravrand, Opalesque Geneva: Before starting his boutique in 2010, Arnaud Chretien, co-founder and CIO of Aequam Capital, worked ten years as a market trader and 18 years as a quantitative and systematic fund manager for Soc

 

banner