Treasury Weighing Action on Hedge Fund Tax Provision

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Sept. 11 — The Treasury Department said it is considering ways to end a tax code provision that allows hedge fund managers to avoid taxes by routing their investments through an insurance company in low-tax countries like Bermuda.
Treasury, in an Aug. 9 letter obtained by Bloomberg News Sept. 11, told Senate Finance Committee Chairman Ron Wyden (D-Ore.) that it is concerned about such arrangements and is weighing legislative and administrative responses.
Among the hedge fund managers who have set up Bermuda insurance vehicles in recent years are John Paulson's Paulson & Co. and Steven A. Cohen's SAC Capital Advisors LP. Cohen has since cut ties with his insurer.
In June, Wyden pressed Treasury to explain why hedge fund insurers continue to proliferate after the Internal Revenue Service promised a crackdown in 2003 (117 DTR G-3, 6/18/14).