2017 Essential Tax and Wealth Planning Guide slide image

2017 Essential Tax and Wealth Planning Guide

Ω Tax implications of fund investing What is an investment fund? . Introduction What is an investment fund? Types of investment funds and income tax characteristics • Marketable securities Hedge funds • Private equity/venture capital Publicly traded partnerships Real estate funds . Fund of funds Investment fund attributes • Trader versus investor entities Passive versus non-passive income Separately stated activity (including PTPs) Qualified small business stock (QSBS) Unrelated business taxable income • State tax reporting Conclusion . Resources The popularity of funds continues to grow, and as of December 31, 2015, it was estimated that $3.65 trillion was invested globally into private equity and $2.8 trillion² was invested into hedge funds. Investment funds are types of investment companies that are typically organized as partnerships. An investment company invests the money it receives from investors on a collective basis, and each investor generally shares in the profits and losses in proportion to the investor's interest in the investment company. The performance of the investment company will be based on (but it will not be identical to) the performance of the securities and other assets that the investment company owns. The focus of this summary is on investment companies organized as partnerships, which are typically described as investment funds. These investment funds are typically structured as partnerships for tax purposes, either as limited partnerships (LPs) or limited liability companies (LLCs). The partnership tax structure is typically used by investment funds, rather than a corporate investment vehicle, to allow for the investment fund's income to be taxed at the investor level and provide for flow-through treatment of income, expense, gains, and losses. Although mutual funds are a type of investment company, they are typically organized as corporations and will not be addressed in this summary. Investors in investment funds include pension funds, sovereign wealth funds, endowment plans, family offices, high- net worth individuals, foundations, and insurance companies. Funds may be referred to as alternative investments and commonly include marketable security funds, hedge funds, private equity funds, and real estate funds. The popularity of funds continues to grow, and as of December 31, 2015, it was estimated that $3.65 trillion' was invested globally into private equity and $2.8 trillion² was invested into hedge funds. A more detailed discussion on the different types of funds available for investment follows. E 今 <弓 ☑ |||| A By Deloitte estimate, based on prorating the $3.5T figure from Preqin data as of June 2015, forward to December 2015. © 2016 Preqin Ltd. www.preqin.com. Note: Venture capital data are excluded from this number. 2 BarclayHedge Ltd. Data as of December 2015, www.barclayhedge.com. 2017 Essential Tax and Wealth Planning Guide | Tax implications of fund investing 46
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