Using Pooled Income Funds to Reduce Taxes on Repatriated Offshore Carried Interest
Author: Gerald R. Nowotny.
Source: Volume 34, Number 01, Fall 2016 , pp.89-100(12)
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Abstract:
The repatriation of deferred carried interest allowed hedge fund managers and private equity managers to defer substantial amounts of performance fees that otherwise would have been immediately taxable. As the deadline for repatriation, December 31, 2017, approaches, investment managers have restarted the search for a miracle solution to the tax problem. The pooled income fund in the current low interest rate environment is a tax solution that heretofore has not entered the discussion.Keywords: IRC Sec. 457A, pooled income fund, IRC Sec. 642(c)(5) requirements, charitable lead annuity trust, charitable remainder trust, charitable split annuity
Affiliations:
1: Law Office of Gerald R. Nowotny.