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    Carried Interest in the Context of Venture Capitalists Business Bad Debt Deduction

    Article The Tax Court held that a venture capitalist’s $3.6 million bad debt was incurred in connection with his carrying on a trade or business of managing venture capital funds and was fully deductible as an ordinary loss under Sec. 166(a).
    Published on January 13, 2012

    Carried Interest in the Context of Venture Capitalists Business Bad Debt Deduction

    Article The Tax Court held that a venture capitalist’s $3.6 million bad debt was incurred in connection with his carrying on a trade or business of managing venture capital funds and was fully deductible as an ordinary loss under Sec. 166(a).
    Published on January 13, 2012

    Tiered Partnerships Will Net Investment Income Tax and Proposals to Change Taxation of Carried Interests Wreak Havoc

    Article Tiered partnerships could become subject to ordinary income tax treatment on many forms of revenue that had previously enjoyed a lower capital gain tax rate.
    Published on July 31, 2013

    Tiered Partnerships Will Net Investment Income Tax and Proposals to Change Taxation of Carried Interests Wreak Havoc

    Article Tiered partnerships could become subject to ordinary income tax treatment on many forms of revenue that had previously enjoyed a lower capital gain tax rate.
    Published on July 31, 2013

    Navigating the Net Investment Income Tax Key Issues for Investment Funds and Their Partners

    Article This item summarizes the aspects of the net investment income tax that are most relevant to hedge fund investors and general partners.
    Published on September 30, 2014

    Navigating the Net Investment Income Tax Key Issues for Investment Funds and Their Partners

    Article This item summarizes the aspects of the net investment income tax that are most relevant to hedge fund investors and general partners.
    Published on September 30, 2014

    The Targeted Allocations Approach A Basic Primer

    Article This item discusses a growing trend in the allocation provisions of partnership agreements in which limited partnerships have been adopting a targeted allocation approach through which “tax follows cash.”
    Published on April 17, 2012

    The Targeted Allocations Approach A Basic Primer

    Article This item discusses a growing trend in the allocation provisions of partnership agreements in which limited partnerships have been adopting a targeted allocation approach through which “tax follows cash.”
    Published on April 17, 2012

    Lack of Limitation Period on Certain Adjustments Affirmed in Recent Decision

    Article A recent case illustrates that courts may sustain the government when it makes adjustments to closed years only to determine whether an overpayment of tax exists, and not to recover additional taxes beyond the limitation period on assessment.
    Published on January 28, 2011

    Lack of Limitation Period on Certain Adjustments Affirmed in Recent Decision

    Article A recent case illustrates that courts may sustain the government when it makes adjustments to closed years only to determine whether an overpayment of tax exists, and not to recover additional taxes beyond the limitation period on assessment.
    Published on January 28, 2011

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