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BNA Tax Portfolio Discusses Tax Aspects of Hedge Funds

NEWS RELEASE

Contacts:
Mark Carrington
(202) 530-1728

Washington, DC (May 17, 2007) – BNA®, publisher of the authoritative and universally recognized Tax Management Portfolios, has released the latest addition to the U.S. Income series, Portfolio 736, Hedge Funds.  The Portfolio addresses the full range of U.S. tax issues that typically arise in the representation of hedge funds and provides guidance to tax practitioners who regularly advise hedge funds, their portfolio managers and their investors. It also describes basic fund prototypes, the relevant regulatory environment and alternative fund structures.

The Hedge Funds Portfolio examines the special tax issues affecting the general partner and its members; foreign and tax exempt investors; and U.S. individuals.  Highlights of the Hedge Funds Portfolio include a detailed description and analysis of the use of the partnership form by most hedge funds, incentive allocations and fee deferrals to the fund manager (including the implications of new §409A), mark-to-market accounting to establish “book” capital accounts and the resulting tax implications, the use of offshore entities, the deductibility of management fees and other expenses.  In addition, the Hedge Funds Portfolio addresses a range of special tax issues raised by certain types of hedge funds investments, including “loan origination”. 

This Portfolio may be cited as Needham and Brause, 736 T.M., Hedge Funds.

Andrew W. Needham is a tax partner with Cravath, Swaine and Moore LLP, where his practice focuses on advising clients on tax aspects of private equity funds, mergers/acquisitions, spin-offs and general tax planning for the preservation of net operating losses and other tax attributes.  Mr. Needham received a J.D. and an LL.M. (Taxation) from Georgetown University Law Center; an M.B.A. from The Wharton School; and a B.A. from the University of Arizona.  He is a Member of the Executive Committee, Tax Section of New York State Bar Association, the American Bar Association, and the United States Tax Court. 

Christian Brause is a tax associate with Cravath, Swaine and Moore LLP.  His broad practice focuses on advising clients on tax aspects of domestic and international acquisitions, spin-offs and other restructurings, corporate and partnership joint ventures, financing transactions (including financial products), private equity funds and real estate funds (including REIT aspects). Christian Brause received a First and Second State Examinations in Rhineland-Palantinate, Germany; a doctorate in law (Dr. jur.) from Johannes Gutenberg University at Mainz; and an LL.M. (Int. Taxation) from New York University School of Law.  He is a former Member of the Bar of Frankfurt a. M., Germany and is currently a Member of the Tax Section of the New York Bar Association

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About BNA®
BNA is a leading publisher of print and electronic news, analysis, and reference products, including the recently launched Accounting Policy & Practice Series.  BNA publications intensely cover legal and regulatory developments for professionals in business and government. BNA is the oldest wholly employee-owned company in the United States, and produces more than 350 news and information services — including Daily Labor Report and Daily Tax Report — widely respected for comprehensive and objective reporting and analysis.

For more information, contact Mark Carrington, BNA Tax & Accounting, at 202.530.1728.