Abstract

http://ssrn.com/abstract=1078118
 
 

Citations (2)



 
 

Footnotes (214)



 


 



Taxation of US Tax-Exempt Entities' Offshore Hedge Fund Investments: Application of the Section 514 Debt-Financed Rules to Leveraged Hedge Funds and Derivatives and the Case for Equalization


Summer A. LePree


KPMG International, LLP


Tax Lawyer, Spring 2008

Abstract:     
Several tax issues involving hedge funds have been receiving substantial attention, both in the media and in Congress. One of these issues involves the immense amounts being invested in offshore hedge funds by tax-exempt entities such as university endowments and pension trusts. These investments are made offshore, in sunny spots like the Cayman Islands, to enable these tax-exempt investors to avoid tax liability. If the same investments were made domestically, the tax-exempt investors would be subject to tax at a rate of 35% on some portion of their investment income. This paper examines this disparate tax treatment and the history and policy behind the rules that give rise to it, and then considers several potential means of equalization.

Number of Pages in PDF File: 91

Keywords: Hedge funds, blocker corporations, tax-exempt organizations, debt-financed rules, unrelated business income tax, taxation of derivatives, endowment, pension fund, leverage

JEL Classification: K34, E62, H2

Accepted Paper Series


Download This Paper

Date posted: December 24, 2007  

Suggested Citation

LePree, Summer A., Taxation of US Tax-Exempt Entities' Offshore Hedge Fund Investments: Application of the Section 514 Debt-Financed Rules to Leveraged Hedge Funds and Derivatives and the Case for Equalization. Tax Lawyer, Spring 2008. Available at SSRN: http://ssrn.com/abstract=1078118

Contact Information

Summer A. LePree (Contact Author)
KPMG International, LLP
200 S. Biscayne Blvd.
Suite 2000
Miami, FL 331
Switzerland
Feedback to SSRN


Paper statistics
Abstract Views: 4,434
Downloads: 924
Download Rank: 12,471
Citations:  2
Footnotes:  214

© 2014 Social Science Electronic Publishing, Inc. All Rights Reserved.  FAQ   Terms of Use   Privacy Policy   Copyright   Contact Us
This page was processed by apollo5 in 0.328 seconds