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Pilgrim’s Pride is Reversed in the 5th Circuit

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February 26, 2015
Pilgrim’s Pride is Reversed in the 5th Circuit

Over a year ago, Pilgrim’s Pride litigated a Section 1234A issue in the Tax Court. The issue was whether the taxpayer could claim an ordinary business loss on the abandonment of securities, and more importantly, whether  Section 1234A applies to the direct abandonment of securities as compared to the abandonment of “rights with respect of” securities....
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CCA 201507019 – Sec. 7701(g) Nonrecourse Debt Relevant for Sec. 475 Mark-to-Market, IRS Says

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February 18, 2015
CCA 201507019 – Sec. 7701(g) Nonrecourse Debt Relevant for Sec. 475 Mark-to-Market, IRS Says

Here we have what appears to be a novel issue that could potentially resolve some confusion that various securitization financial players might have had in the past. The question CCA 201507019 answers is whether financial institutions who mark-to-market their portfolios under Sec. 475 must factor in their fair market value calculations any Sec. 7701(g)...
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SIFMA asks the IRS to issue a FAQ regarding “document repositories” under Regulations 1.1471-3(c)(6)(iv) and 1.1441-1(e)(4)(iv)(C)

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February 10, 2015
SIFMA asks the IRS to issue a FAQ regarding “document repositories” under Regulations 1.1471-3(c)(6)(iv) and 1.1441-1(e)(4)(iv)(C)

We wanted to pass the following along in case you missed it. Apparently SIFMA members, who encompass some of the largest investment funds and financial institutions in the Country, are in a predicament regarding document repositories and whether current practices with respect to those repositories meet FATCA regulations. Investment managers have to provide various...
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Private Equity Management Fee Waivers – the Latest by Andy Grewal, Gregg Polsky and Others

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February 4, 2015
Private Equity Management Fee Waivers – the Latest by Andy Grewal, Gregg Polsky and Others

This is not breaking news, but in light of the supposedly upcoming guidance regarding management fee waivers, we wanted to write a short bit about the status quo. We also want to highlight an article by Andy Grewal, which we thought did not get sufficient exposure commensurate with its quality.  First a short description...
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Partnership Interest in A Scratch-and-Dent Distressed Debt Master Fund Qualifies as a “registered form obligation”

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January 26, 2015
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PLR 201504004 is a bit of an esoteric ruling. It deals with the narrow issue of the availability of the Reg. 1.871-14(a) portfolio interest exemption to funds that invest in distressed securities that are not in registered form. As a background, the portfolio interest exemption provides that the receipt of interest is not subject to...
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