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2.42 MB
Extraction Summary
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Quotes
Document Information
Type:
Legal/tax memorandum
File Size:
2.42 MB
Summary
This document is a page from a tax advisory memorandum discussing changes brought about by 'the Tax Act' (referencing the Tax Cuts and Jobs Act of 2017). It analyzes the implications of the new qualified business income deduction for pass-through entities and the repeal of miscellaneous itemized deductions for non-corporate taxpayers. The text highlights specific challenges for investment managers, financial service providers, and partnership funds, noting that high net worth US individuals might prefer offshore corporate feeder funds due to these tax changes. The document originates from a House Oversight production.
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Congress | ||
| Internal Revenue Service |
Key Quotes (4)
"Congress also wanted to provide an income tax rate reduction for those businesses that are organized as partnerships or S corporations"Source
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Quote #1
"Therefore, fund managers organized as pass through entities are not likely to, and investment funds organized as partnerships will not, derive a significant benefit from this deduction."Source
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Quote #2
"This Tax Act change obviously puts considerable strain on the fund manager and its tax advisors with respect to the trader vs. investor issue."Source
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Quote #3
"US high net worth individuals may now prefer to invest in the offshore corporate feeder fund instead of the onshore partnership fund."Source
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Quote #4
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