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Piggybacking and Double-Dipping: What Asset Managers Can Learn From the Life Sciences’ Experience With the SEC and the IRS  


Author:  Kat Gregor.; Nicholas Berg.; Bradley Lewis.


Source: Volume 30, Number 01, Fall 2016 , pp.11-22(12)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

The IRS has recently brought its strategy of piggybacking onto SEC, DOJ, and other agencies’ enforcement efforts to the asset management industry. This corresponds with an uptick in actions brought by the SEC against the private equity and hedge fund industries. Asset management businesses facing a regulatory examination therefore must be cognizant of the likely threat of follow-on action. Once the SEC shows up, savvy asset managers should begin preparing for the IRS.

Keywords: SEC regulatory examination; IRS follow-on action; deductibility of disgorgement payments; tax deduction; Advice Memorandum 201619008; Nacchio v. U.S.

Affiliations:  1: Ropes & Gray LLP; 2: Ropes & Gray LLP; 3: Ropes & Gray LLP.

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