Hedge Fund Taxation: Advanced Issues


Tax issues for hedge funds and their investors can be extremely complex. This unique workshop addresses these issues and focuses on:

  • Tax reporting and emerging state and local taxation issues for hedge funds and their investors
  • Discussion of common tax adjustments affecting hedge funds
  • Tax allocations and mandatory basis adjustments



To provide tax professionals who work with hedge funds and their investors with in-depth analysis of current income tax issues covering taxation of financial products used by hedge funds and how the fund is taxed. You will be able to recognize important issues, know where to look for help and how to avoid the most common errors, and understand the requirements for  continuing compliance efforts under FATCA (Foreign Account Tax Compliance Act) and related rules of Non-US Regulators. The course highlights the most recent developments coming out of the IRS's increasing emphasis on technical rulings and audits of hedge funds and their managers.

  • Update on current developments
  • The impact of the Tax Cuts and Jobs Act of 2017 on:
    – Taxation of the hedge fund industry and its participants (carried interest; qualified business income exclusion)
    – Cryptocurrency assets
    – Partnership audit rules: how to draft for the new regime
  • Review of current hedge fund structures
    – Onshore vs. offshore funds
    – Principal tax consequences for each structure
    – Methods of tax accounting
  • Information reporting, particularly foreign accounts
  • Tax allocations for hedge funds and the most common errors
  • Structuring incentive-based returns for managers—latest word on carried interest repeal legislation and the IRS's push for more self-employement income by managers
  • Taxation of financial products, including swaps, passive foreign investment companies and debt instruments
  • Commodities and Forex Contracts—Section 1256
  • Financial instruments, including distressed debt strategies
  • Unrelated Business Taxable Income (UBTI)
  • IRS “audit red flags,” including Forms 8275 and 8275-R Return Disclosure, Deductions for Organization/Syndication Costs
  • Critical issues in preparing the hedge fund’s partnership return and the K-1s for investors and an update on information returns, particularly IRS international forms

Basic knowledge of hedge funds formation, operation and taxation.


No advance preparation required.

Level of Knowledge: 


CPE Credit: 
NASBA Field of Study: