Tax Planning For U.S. Hedge and Equity Funds
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Your master and feeder funds will benefit from the creation of a tax plan that includes an exempt offshore fund to protect foreign investors and reducing their taxes.
Structuring of Funds
Funds typical structure is design as a master fund structure. This is the cornerstone to protect investors and create a classification for U.S., foreign and non-profit clients. The master fund will be divided into a U.S. Feeder Fund and a Foreign Feeder Fund. Within the same structure the investment manager is also a foreign entity. There are many offshore jurisdictions such as Cayman, Bermuda or Bahamas that can be used as the base for the foreign feeder fund and the investment manager. Cayman is usually the location of choice for many reasons, including its proximity to the U.S. and its legislation in addition to be a first tier offshore center.
Tax Planning
The complexity of operational challenges and internal structuring result in the need for tax planning for: Cash flow distributions Valuation Distribution Diversification Transfers Finally with the Trump Tax Reform, fund managers should consider changes to the fund structure as the result of important tax changes: Carried interest: if a partnership interest is sold before 3 years the sale is taxable at regular tax rates.
Tax Changes
Itemized deduction: management fees are not tax deductible anymore until 2025. 20% Business income deduction: fund partners are allowed 20% income deduction subject to W2 wages paid. Business loss limitation: fund partners losses are limited to $250K if single, double if married. Any excess will be carried forward. Controlling Foreign Corporation (CFC): income from CFC is taxable and should be included into partners personal tax return subpart F.
Subscription Plans
Silver
$900
/ Per Month
- Accounting Services Up To 3 Bank Accounts
- 3 Bank Accounts Reconciliation
- Monthly Classification of Transactions
- Month-end Closing
- Tax Return Filing Up To 10 K1s
Gold
$1.5K
/ Per Month
- Accounting Services Up To 6 Bank Accounts
- 6 Bank & Credit Card Accounts Reconciliation
- Monthly Classification of Transactions
- Month-end Closing
- Tax Return Filing Up To 15 K1s
- External Payroll Registration
Platinum
$3K
/ Per Month
- Accounting Services Up To 6 Bank Accounts
- 6 Bank & Credit Card Accounts Reconciliation
- Monthly Classification of Transactions
- Month-end Closing
- Tax Return Filing Up To 20 K1s
- External Payroll Registration
- Annual Audit Report
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Accounting Firm providing Accounting & Bookkeeping, Tax Planning and Offshore Strategies to grow your business and protect your assets.
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President
Thanks to FAS & CPA Consultants and Fulton Abraham Sanchez, CPA, I was able to resolve a debt of $479,677.71 that I had with the IRS.
Entrepreneur
My experience with FAS CPA & Consultants has been incredible, their professionalism is impeccable. I highly recommend them.
Manager
I highly recommend FAS CPA & Consultants, they are responsible, efficient and very dedicated.
Manager
Fulton is a wonderful CPA who fully understands tax law and provides honest advice for his clients.