Investment Company Tax

Unmatched Investment Industry Tax Expertise

Our team focused on investment company tax provides a best-in-class solution: offering 100% focus on the investment industry with an innovative approach and flexible model to meet the diverse tax demands of registered and alternative investment funds. Our large group of dedicated tax practitioners has years of experience delivering a full range of tax services with one goal in mind: to improve the efficiency and effectiveness of your tax function, identifying favorable tax opportunities for general partners/managing members and investors.

We provide tailored tax solutions to funds, advisers and service providers of all types and sizes, including mutual funds, closed-end interval funds and master limited partnership funds; exchange-traded funds; hedge funds and alternative investment funds; collective investment trusts; investment advisers and service providers. In fact, we work with some of the largest institutional investment managers in the country. Our work makes us one of only 14 firms in the country with more than 100 public company clients, all investment clients. And while a number of our professionals come from Big 4 backgrounds, all of our associates are trained to conduct national firm-caliber work. As a result of our highly regarded expertise, members of our firm serve or have served on numerous prominent industry boards and committees, such as the AICPA’s Board of Directors, Investment Companies Expert Panel and Digital Asset Working Group; ICI Tax Advisory Group; various industry committees; regional hedge fund associations and SEC working groups. We have also received the distinction of "Best Tax and Audit Provider” in the 2022 and 2023 Hedgeweek U.S. Digital Asset Awards for our work with digital asset clients.

Our Investment Company Tax Services

Our flexible model allows you to receive the entire spectrum of tax services* or only select services — depending on what fits your needs.

Compliance

• Preparation of federal, state, and local tax returns and extensions

• Preparation and proactive tax planning related to fund general partners/managing members, advisers, management companies and broker-dealers

• Assistance with state nexus issues and evaluation of related filing requirements

Tax Planning, Consulting and Structuring

• Review of portfolio holdings to identify and analyze complex securities and derivative instruments for tax purposes

• Review of corporate actions associated with portfolio holdings resulting from mergers, reorganizations and return of capital distributions

• Identification and tracking of wash sales, tax straddles and constructive sales

• Consultation regarding U.S. tax withholding obligations and related filings

• Consultation on onshore and offshore fund structuring, effectively connected income, ERISA and UBTI

• Assistance with fund launch issues, such as selection of tax year-end, initial contribution of securities, and establishing tax-efficient policies and positions in the initial year

• Assistance with fund mergers and liquidations, including limitations on use of capital loss carryforwards and determination of final distributions for registered funds

• Analysis of new products and investment opportunities

Excise Distributions (Registered Funds)

• Preparation/review of excise tax distribution requirements, including assistance with estimates

Year-End Tax Provision Preparation (Registered Funds)

• Preparation of comprehensive year-end tax package for auditor, including taxable income and gain/loss calculations, preparation of financial statement footnotes and disclosures, SOP 93-2 (ROC SOP) calculations and disclosures, and ASC 740 documentation and calculations (including foreign capital gains tax calculations)

Strategies - Tax Qualification Testing (Registered Funds)

• Timely review of quarterly asset diversification tests, including Section 817(h) and gross income tests

• Analysis of certain types of portfolio holdings, such as partnerships and trusts, to assess their implication on the tax qualification tests and taxable income calculations

Tax Opinions and Ruling Requests

• Tax opinions and memoranda on complex tax issues

• Representation before the IRS, including letter ruling requests

Internal Tax Inquiries

• Assistance with internal tax-related consultations with other departments, such as portfolio management, marketing and fund accounting

Other Tax Functions

• Assistance with shareholder information reporting for registered funds, including tax character of distributions (ordinary, tax exempt, capital gain, return of capital) and other tax attributes and pass-throughs such as QDI, interest-related and short-term capital gain related dividends, foreign tax credits and foreign source income

• Evaluation of filing for potential foreign tax reclaims

• Analysis of distributions received from REITs and related tax cost basis tracking

• Customized training courses and current development sessions covering tax, accounting and regulatory topics

_{* Some tax services may be prohibited if the fund is also an audit client of the firm}