Traditionally fund managers have avoided most illiquid investments due to their perceived misalignment with the Investment Company Act of 1940. However, in recent years there has been a convergence in asset classes in search of new investment opportunities. With that, we have seen an...
Read MoreCohen & Co’s Milwaukee office began as a natural extension of the firm’s basic tenets — one of which is empowering young leaders to take risks in an environment rich with great relationships, clients and employee talent. It was the perfect recipe for a growth story! As I...
Read MoreU.S. taxpayers who invest in debt instruments not denominated in U.S. dollars are often interested in hedging the currency exposure of these types of investments. This is commonly accomplished with an investment into a forward contract, futures contract, options contract or other instrument...
Read MoreSince the enactment of the Tax Cuts and Jobs Act of 2017 (TCJA), there has been a lot of concern about the deductibility of investment advisory fees. The TCJA repealed the miscellaneous itemized deductions for individual taxpayers’ investment advisory fees for tax years 2018 through 2025. ...
Read MoreRegulated Investment Companies (RICs) regularly invest in entities classified as partnerships for U.S. tax purposes. It is important for RIC managers to understand the different types of partnership investments, most notably whether or not a publicly traded partnership (PTP) you may be investing...
Read MoreThe IRS has released final Treasury Regulations under IRC Section 1061. The 2021 final regulations supplement the legislation enacted under the Tax Cuts & Jobs Act (TCJA) of 2017 and revise the proposed carried interest regulations issued in July 2020. The final regulations are generally less...
Read MoreThe evolution of the financial system in the United States — as well as the growing ubiquity of financial derivatives and hedging strategies — has created the need for a federal tax code that is likewise able to evolve. One such evolution found in the Taxpayer Relief Act of 1997 is...
Read MoreOn January 5, 2021, the Department of the Treasury released new final regulations pertaining to the deductibility of business interest expense under IRC Section 163(j). These regulations supplant proposed regulations issued in November 2018 and July 2020, and supplement final and proposed...
Read MoreRecent trends in the cryptocurrency marketplace have indicated an increased interest in activities connected with Proof of Stake (PoS) cryptocurrencies, whether used with the intent of receiving regular income from PoS rewards or engaging in other income generating activities in a decentralized...
Read MorePart I of this blog post offered background on cryptocurrencies, including the different types, how to value them, and how they generally are taxed at the individual level. This post will discuss more specific strategies related to types of taxation, strategies to minimize tax and how to keep...
Read More