Taxation
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Providing advice to investment adviser clients and the investment vehicles they manage as it relates to broker-dealer IRS tax reporting of their respective U.S. and non-U.S. investors;
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Providing guidance to investment adviser clients and the investment vehicles they manage as it relates to broker-dealer account opening;
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Providing advice regarding the applicability of the prohibited transactions provisions of the IRC to specific fund transactions;
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Advising fund managers and investors as to the consequences of making contributions to investment vehicles from IRA assets;
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Performing a tax election on behalf of a non-U.S. company to be treated as a U.S. partnership for tax purposes;
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Performing a tax election on behalf of a non-U.S. limited partnership to be treated as a U.S. corporation for tax purposes; and
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Establishing "master-feeder" structures to accommodate the tax concerns of both U.S. investors and non-U.S. investors investing in a single portfolio.