Tag: PIF
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Pooled Income Funds for the Repatriation of Offshore Carried Interest
Looking Over the Edge of the Cliff – The Use of Pooled Income Funds for the Repatriation of Offshore Carried Interest Overview The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge…
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End of the Line – Part II: Year End Tax Planning Strategies
This article is Part II in a series of tax planning strategies for year-end tax planning for the 2015 tax series. The article addresses the Pooled Income Fund (PIF) which as this article demonstrates, has surprising planning utility in the current low interest rate environment. Planned giving officers of tax exempt organizations are very familiar…