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U.S. Taxation of Sovereign Wealth Fund Investments in Funds (and Real Estate): Where We Stand Today  


Author:  William M.  Funk.


Source: Volume 30, Number 04, Summer 2013 , pp.43-50(8)




Journal of Taxation of Investments

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Abstract: 

This article reviews the U.S tax regimes that apply to investments by sovereign wealth funds in the United States, with a particular focus on U,S, real property. The author then explains the interaction of these tax regimes and recently promulgated regulations on typical investment structures, distills the rules into analytical principles for reviewing investments by sovereign wealth funds in the U.S., and provides examples of typical fact patterns and how they are affected by these tax regimes and principles.

Keywords: IRC Sec. 892; partnership disposition rule; FIRPTA; controlled entity; commercial activity; controlled commercial entity; hedge fund

Affiliations:  1: Attorney at Law.

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