This article, which will be expanded in the next issue of Corporate Taxation, discusses a recent Tax Court decision that raises the question whether hedge funds and private equity firms segregating large capital investments by non-U.S. persons, foreign countries, and exempt organizations, for investment in the U.S. in foreign feeder groups, are imputed the status of being engaged in one or more U.S. trades or businesses through the activities of their agents. In YA Global Investments, LP, 161 TC…
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The new tax law enacted in December swapped out a graduated corporate tax rate topping out at 35 percent with a flat 21 percent rate across the board. While this provision, combined with the elimination of the corporate alternative minimum tax (AMT), might seem to have simplified matters considerably, attorney Jerald David August, a tax partner at Kostelanetz & Fink, LLP, who spoke at the Foundation for Accounting Education’s conference “Impact of the New Tax Law: a Sid Kess Work…
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