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Abstract: 

Surveys several important IRS rulings and regulations, Appeals Court decisions, and GAO and other reports: including: Debt Issuance Costs Not Considered in Determining Exercise Date of Call Option on Debt (PLR 200525001); Disregarded Entities Separately Liable For Periods in Which They Were Not Disregarded (IRC Sections 856, 1361, and 7701; Qualified Matching Service for Hedge Funds Avoids Established Securities Market Designation and Corporate Treatment (PLR 200507001); Fiduciary Duty Could Apply to Underwriter, New York Court Rules (New York State Court of Appeals); Hedge Fund Regulation Considered by UK’s Financial Services Authority; GAO Looks at SEC’s Neglect of Market Timing Abuses

Keywords: PLR 200525001; IRC Sections 856, 1361, and 7701; PLR 200507001; SEC and Market Timing Abuses

Affiliations:  .