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Qualified Matching Service for Hedge Funds Avoids Established Securities Market Designation and Corporate Treatment  (Market Notes)


Author:  John Ensminger.


Source: Volume 22, Number 04, Summer 2005 , pp.343-348(6)




Journal of Taxation of Investments

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Abstract: 

In PLR 200507001, the taxpayer requested rulings that certain services were not established securities markets under Section 7704, and that one of the services was a qualified matching service under Reg. 1.7704-1(g). If the Service granted these requests, which it did, the taxpayer also requested that partnerships whose interests were offered on the services would not be publicly traded as a result of these offerings. The latter ruling was also granted, providing the representations were correct.

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