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Terhune Articles


Welcome to Capital Management Services Group
Offering Advice & Services to Traders | Investors | Funds
Leading Media Articles on Hedge Funds and International Taxes
Our Customers
We interviewed several firms in regards to creating a incubator fund for our firm, after an exhaustive interview process we were most impressed with Hannah and her team.  Hannah under promised and over delivered, our documents were created and filed in an incredibly timely and cost effective manner.  We will undoubtedly continue to work with Hannah and her team in the future as they have proven to be an valuable asset to our firm.  Txxxxx Xxxxxn May 09, 2012

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Meet Hannah Terhune
Hannah Terhune, Attorney, contributes current expertise to many online and magazine repositories, as does Jim Brennan, Attorney.  These articles are widely circulated.

Strategic Hedge Fund Planning by Hannah Terhune.  Canadian Hedgewatch (March 2012).

Strategic Hedge Fund Planning by Hannah Terhune.  MoneyScience (March 2012)

Hedge Funds - Limited Partners' Right of Access After Parkcentral Global, L.P., v. Brown Investment Management, L.P. by Jim Brennan.  Canadian Hedgewatch (July 2011).

Planning for Cross-Border Financing Arrangements.  Practical International Tax Strategies (May 31, 2011).

U.S.--Tax Traps of Non-U.S. Issuer Debt Offerings.  Practical International Tax Strategies (April 15, 2011).

America the Beautiful Tax Haven.  Cititrust Edge Magazine (1st Quarter 2011).

Offshore Hedge Fund Focus:  Master & Feeder.  Cititrust Edge Magazine (4th Quarter 2010).

U.S.--Cross Border Credit Agreements:  Planning for U.S. Withholding Taxes.  Practical International Tax Strategies (November 15, 2010).

Starting an Offshore Fund.  themanager.org (June 2008).

Mixing Investment Adviser and Brokerage Services.  Hedge Fund Monthly (October 2007).

Offshore Fund Taxation.  Hedge Fund Monthly (May 2007).

Forex Trader to Forex Manager.  Offshore Business Magazine (November 2006).

Forex Trader to Forex Fund Manager:  The Path to Success.  Hedge Fund Monthly (October 2006).

Drafting Hedge Fund Performance Allocations. Hedge Fund Monthly (August 2006).

Como Crear su Propio Hedge Fund by Hannah M. Terhune, Eva Porras, Argilio Rodriguez and Garrett Fisher (2006)

Offshore Hedge Funds: Focus on Master/Feeders by Hannah M. Terhune (2006)

Temas Sobre Impuestos de Sociedades Colectivas para Hedge Funds en Paraiso Fiscal by Hannah M. Terhune (2006)

Establish a Marketable Track Record with an Incubator Fund by Hannah M. Terhune (2006)

Must I Register as a Commodity Pool Operator? by Hannah M. Terhune (2006)

Do’s and Don’ts for Crafting Hedge Fund Peformance Allocations by Roger D. Lorence and Hannah M. Terhune. Derivatives:
Financial Products Report (an RIA publication) (September 2005)

Trading Foreign Index Contracts? Know the Tax Rules Before You Trade by Hannah M. Terhune and Roger D. Lorence. Stocks, Futures and Options (June 2005)

Practical Strategies For Section 475(f) Elections by Roger D. Lorence and Hannah M. Terhune. Derivatives Financial Products Report (WG&L/RIA,a Thompson Company) (March 2005)

Forex Hedge Fund Management by Hannah Terhune and Roger D. Lorence.  Currency Trader (March 2005).

Advising Clients on Internet Server Co-Location Agreements, Practical International Tax Strategies (March 15, 2004)

Structuring and Financing International Operations Using Hybrid Entities and Tax-Efficient Financing. Practical International Tax Strategies (Jan. 15, 2004)

Hedge Fund Compensation Arrangements. Practical U.S./Domestic Tax Strategies (Dec. 2003)

U.S. Inbound Investment – The Portfolio Interest Exemption. Practical International Tax Strategies (Dec. 15, 2003)

Business Acquisitions: Key Tax Planning Issues. Practical U.S./Domestic Tax Strategies (Sept. 2003)

Foreign Futures Planning: The 60/40 Question. Practical International Tax Strategies (Sept. 30, 2003)

Managing Offshore Hedge Funds – A View from the Beach: Practical International Tax Strategies (June 15, 2003)

A Practical Defense of the Family Limited Partnership: Practical U.S./Domestic Tax Strategies (May 2003)

Offshore Hedge Funds – Master/Feeder Compliance Issues: Practical International Tax Strategies (May 15, 2003)


Our Customers
We would like to thank Hannah and the company for their invaluable help in forming our incubator hedge fund. They were extremely knowledgeable, efficient, and professional while working with us, and we are glad to have them as a vital resource as we grow our incubator hedge fund into a full-fledged one. Dale Angus, Golden Egg Capital Management LLC. March 28, 2012.

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Our Customers
Thank you - Money Science  Your explanation of how to start a hedge fund is so clearly stated and easily understood. This should be a chapter in a high school text book or at least minimum college reading.  I read it with interest in potentially starting my own hedge fund.  I fall within the scope of "Hedge Fund Incubator".  I know this article is a few years old but again well worth reading. I may seek your services and have since bookmarked your page.  Thank you again. Jxxx  Xxxxx  January 6, 2012

Tax-Free Asset Acquisitions – More Strategies for S-Corporations: Sourcing Income to Preserve the Use of Credits and Carryovers: Practical International Tax Strategies (April 15, 2003)

Reducing Operational and Exit Taxes On Closely-Held Businesses. Practical U.S./Domestic Tax Strategies (August 2003)

Coming Ashore – Establishing U.S. Operations: Practical International Tax Strategies (July 31, 2003)

Financing U.S. Business Operations Using Cross-Border Income Trust: Practical International Tax Strategies (July 15, 2003)

Methods of Compensating the Executive – An Overview of Various Tax Features: Practical U.S./Domestic Tax Strategies (May 2003)

Update on Spanish Holding Companies. Practical European Tax Strategies (Aug. 2003)

Self-Employment Tax Planning – LLC to S-Corporation Conversions: Practical U.S./Domestic Tax Strategies (March 2003)

Outbounding Income from Intellectual Property, Practical International Tax Strategies (March 15, 2003)

Taxable Stock Purchases: More Planning Strategies for S-Corporations, Practical U.S./Domestic Tax Strategies (Feb. 2003)

Business Globalization: Selecting the Proper Offshore Entity, Practical International Tax Strategies (Feb. 15, 2003)

Taxable Acquisitions: Financing Asset Acquisitions When an S-Corporation is Involved. Practical U.S./Domestic Tax Strategies (January 2003)

International Joint Venture Partnerships: Foreign or Domestic, Practical International Tax Strategies (January 15, 2003)

Tax Planning for Multiple Corporations: Domestication of Foreign Corporations. Practical International Tax Strategies (Oct. 15, 2002)

Acquisition Techniques Using Partnerships or LLCs – Planning Strategies to Defer Taxable Gain. Practical U.S./Domestic Tax Strategies (Oct. 15, 2002)

Tax Planning for Multiple Corporations: Canadian and Mexican Contiguous Country Companies. Practical International Tax Strategies (Oct. 15, 2002)

Acquisition Techniques Using Partnerships or LLCs – Planning Strategies to Defer Taxable Gain. Practical U.S./Domestic Tax Strategies (Oct. 15, 2002)

Tax Planning for Multiple Corporations: Canadian and Mexican Contiguous Country Companies. Practical International Tax Strategies (Oct. 15, 2002)

Domestic and International Tax Planning for Multiple Corporations. Practical International Tax Strategies (Sept. 15, 2002)

Tax Benefits of Spanish Holding Companies: A Planning Opportunity for U.S. Companies. Practical International Tax Strategies (Aug. 31, 2002)

Key Tax Aspects of International M&A – Planning Scenarios Involving Tax Acquisitions. Practical International Tax Strategies (Sept. 15, 2003)

Corporate-Level Penalty Taxes on S-Corporations – Transaction Costs in Mergers, Acquisitions and Buy-Outs. Practical U.S./Domestic Tax Strategies (December 2002)

Taxation of Foreign Partnership Income: Issues to Consider in Reviewing Foreign Operating Structures. Practical International Tax Strategies (Dec. 31, 2002)

The Future of European-Based Business Operations: A Look at the Tax Aspects of the Societas Europaea. Practical European Tax Strategies (November 2002)

Shifting Intangible Income to an Offshore Company Part II: Sale or License? Practical International Tax Strategies (Sept. 15, 2001)

Shifting Intangible Income to an Offshore Company "Round Tripping" and the Risk of Bringing §956 into Play. Practical International Tax Strategies (Aug. 15, 2001)

Update on Filing Requirements for Transfers of Property Offshore. Practical International Tax Strategies (July 15, 2001)

Want a Multinational Corporation In Your Backyard? Strategic Tax Planning for Countries Without a Clue. Practical International Tax Strategies (June 15, 2001)

Planning Notes for U.S. Businesses Operating Overseas: U.S. Outbound Tax Issues. Practical International Tax Strategies (May 31, 2001)

U.S. Strategic Tax Planning and Other Modern Day X Files An FSA to Remember. Practical International Tax Strategies (May 15, 2001)

More on International Tax Planning for Highly Compensated Individuals Combining Individual Leasing Programs, Deferred Compensation and Rabbi Trusts. Practical U.S./International Tax Strategies (April 30, 2001)

International Tax Planning for Highly Compensated Individuals Taking Advantage of Special Treatment for "Rabbi Trusts." Practical U.S./International Tax Strategies (April 15, 2001)

More on Dealing with Passive Foreign Investment Companies Using Inter-Company Loans, Handling Start-Up Costs and Other Matters. Practical U.S./International Tax Strategies (March 31, 2001)

Our Customers
I would like to state unequivocally that I have had a completely positive experience in dealing with Capital Management Services Group.  Truly, from the first phone call that I made to Capital Management, to the conference call that was arranged with Hannah Terhune, the time she took in answering all of my questions, and, finally, to the follow-up by Amy Hong.  My case involved the establishment of a Forex Incubator Fund, and was thoroughly handled.  Hannah Terhune responded promptly to my subsequent phone calls and Amy Hong is absolutely 100% efficient.  I, certainly, plan to enlist Capital Management's services for my legal needs in the future concerning fund management.  I would rate my experience and results 5 out of 5 stars! Totally satisfied, Rxxxxxx Sxxxx, September 22, 2010

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Dealing with Passive Foreign Investment Companies How the System Works and Strategies to Avoid PFIC Status. Practical U.S./International Tax Strategies (March 15, 2001)

Swiss Corporate Ventures, Inc. – Advantages of Establishing a Holding Company in Switzerland. Practical U.S./International Tax Strategies (Feb. 28, 2001)

Cost-Sharing Rules under IRS Attack, Part IV. Practical U.S./International Tax Strategies (Feb. 15, 2001)

International Tax 101. Practical U.S./International Tax Strategies (Jan. 31, 2001)

International Tax 101: More Cliff Notes to Cross-Border Business. Practical U.S./International Tax Strategies (Jan. 15, 2001)

Cost-Sharing Strategies Under Attack, Part III IRS Challenges to Cost-Sharing Arrangements. Practical U.S./International Tax
Strategies (Dec. 15, 2000)

Cost-Sharing Strategies Under Attack, Part II, Transfer Pricing Rules and Cost-Sharing Arrangements. Practical U.S./International Tax Strategies (Nov. 30, 2000)

Cost-Sharing Strategies Under Attack How Transfer Pricing Rules Affect Cost-Sharing Arrangements. Practical U.S./International Tax Strategies (Nov. 15, 2000)

Dutch Tax Treats Use Them or Lose Them. Practical U.S./International Tax Strategies (Oct. 15, 2000)

Going Global? Go Home – Unless You're Prepared for the U.S. Tax Consequences. Practical U.S./International Tax Strategies (Sept. 30, 2000)

Commissionaire Use in Austria: Focus on a Commissionaire-Friendly Jurisdiction. Practical U.S./International Tax Strategies (Sept. 15, 2000)

Commissionaire Operations in Switzerland. Practical U.S./International Tax Strategies (Aug. 15, 2000)

Using Stripped Subsidiaries for Foreign Country Sales Another Alternative to the Traditional Buy-Sell Model. Practical U.S./International Tax Strategies (July 31, 2000)

Understanding the IRS Multinational Tax Audit. Practical U.S./International Tax Strategies (July 15, 2000)

Handling the IRS Corporate Tax Audit: In Defense of the U.S. Tax Director. Practical U.S./International Tax Strategies (June 30, 2000)

Avoiding Taxable Income by Managing CFC Guarantees of U.S. Parent Company Debt. Practical U.S./International Tax Strategies (June 15, 2000)

Tax Measures to Hedge Against the U.S. Equity Devolution. Practical U.S./International Tax Strategies (May 31, 2000)

Bringing Home the Bacon: Planning Strategies for Offshore Income, Part III. Practical U.S./International Tax Strategies (April 30, 2000)

Commissionaire Use in France: Vetting the VAT. Practical U.S./International Tax Strategies (April 15, 2000)

Bringing Home the Bacon: Planning Strategies for Offshore Income, Part II. Practical U.S./International Tax Strategies (March 31, 2000)

Bringing Home the Bacon: Planning Strategies for Offshore Income, Part I. Practical U.S./International Tax Strategies (March 15, 2000)

Commissionaire Use in Spain. Practical U.S./International Tax Strategies (Feb. 28, 2000)

Commissionaire Use in Belgium. Practical U.S./International Tax Strategies (Feb. 15, 2000)

Crafting the Cross-Border Contract: Foreign Taxes and the U.S. Foreign Tax Credit. Practical U.S./International Tax Strategies
(Jan. 31, 2000)

Crafting the Cross-Border Contract: Structuring a Services Agreement. Practical U.S./International Tax Strategies (Jan. 15, 2000)

Crafting the Cross-Border Contract: Drafting to Obtain Sales or Business Profits Treatment. Practical U.S./International Tax Strategies (Dec. 15, 1999)

Crafting the Cross-Border Contract: Unbundling Show-How from Know-How. Practical U.S./International Tax Strategies (Nov. 30, 1999)

Integrating Commissionaire Operations with Just-in-Time Inventory Controls. Practical U.S./International Tax Strategies (Nov. 30, 1999)

Managing the Cross-Border Payroll, Part II: Withholding and Reporting Obligations. Practical U.S./International Tax Strategies (Nov. 15, 1999)

Managing the Cross-Border Payroll, Part I: Overview of U.S. Payroll Taxes. Practical U.S./International Tax Strategies (Oct. 31, 1999)

Cutting Foreign Tax Costs Using Well Known, Multi-Jurisdictional Tax Planning Strategies. Practical U.S./International Tax Strategies (Oct. 15, 1999)

Structuring an International Joint Venture: Transferring Intangible Property and Other Assets. Practical U.S./International Tax Strategies (Sept. 30, 1999)

Integrating The Foreign Sales Corporation Into Commissionaire Distribution Operations. Practical U.S./International Tax Strategies (Sept. 15, 1999)

Using A Foreign Sales Corporation To Fund An Individual Retirement Account: Some Practical Examples. Practical U.S./International Tax Strategies (Sept. 15, 1999)

Integrating The Foreign Sales Corporation Into commissionaire Distribution Operations. Practical U.S./International Tax Strategies (Aug. 15, 1999)

Commissionaire Modeling for European Union Customer Sales. Practical U.S./International Tax Strategies (July 31, 1999)

Customs Duty Planning for Commissionaire Operations. Practical U.S./International Tax Strategies (July 15, 1999)

Avoiding Foreign Withholding Taxes. Practical U.S./International Tax Strategies (July 15, 1999)

Commissionaire Use in Japan. Practical U.S./International Tax Strategies (June 30, 1999)

Taking Charge of Foreign Profits Through Commissionaire Operations. Practical U.S./International Tax Strategies (June 15, 1999)

Final Regulations Clarify Cost-sharing of R&D Expenditures, The Tax Advisor (January 1997)

Employer Operated Eating Facilities, Journal of Compensation and Benefits (September 1990)


Our Customers
Hannah - I recently read your article entitled How to set up a hedge fund on moneyscience.com.  It was very good.  The detail of the article is unmatched by anything else online.  I really appreciate that.  The only other way to get that information would be to pay a few hundred dollars for a book on the subject.  Thanks for the help! Axxxx Bxxxxxx April 15 2009

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Why Hire Us?
When you engage us for hedge fund you get a unique combination of securities, tax, and international experience, focused on the trader niche.  We have established a leadership position with traders.  We are one destination for all your very special hedge fund and trader tax needs.  We think we have the best set of offering documents based on the current and ever changing federal, state and offshore securities, commodities, and tax laws.  We aim and deliver quick turnaround times, because we understand that our customers want to begin their money management business as soon as possible.  We conceive, structure, and deploy the best tax saving strategies into your hedge fund vehicle (for the benefit of the manager and their investors) and your management company. Investors value tax-savings strategies and we utilize all our special knowledge and ideas in this area.  Our customers value our one-stop relationship.  We will help you start your business and continue to assist you.  Our tax services division handles accounting, software, and tax compliance, including all tax matters (tax planning and tax returns).  Only one thing counts with us and that's our customer relationships!


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CapitalManagementServicesGroup.com is recognized by discriminating fund managers and businessmen as being the foremost tax and legal authority in the business.  Attorney Hannah Terhune's education and experience are unsurpassed in the area of hedge funds creation and management platforms, and the complex body of related tax laws.  Ms. Terhune's extensive knowledge and experience have made her an indispensable resource for serious hedge fund and business professionals.  Ms. Terhune's articles on the subjects have appeared in over 100 publications worldwide.  Chances are, if you have read about the above matters, Ms. Terhune has written about them.
 
Give us the opportunity to use that knowledge and experience for you.  We have both regulatory experience and the understanding of the foreign exchange and securities markets.  We know how to navigate the compliance with rules and regulations in the United States as well as in regulated jurisdictions such as United Kingdom, Singapore, Hong Kong, Canada and the British Virgin Islands.  Each client receives personalized attention from our attorneys and staff.   No client is too large or small though because of our boutique size.  We pride ourselves in providing personal attention to each client.
 
CMSG provides the best services and support needed for hedge funds and business projects.  No need to coordinate work between different firms--we handle the entire business process from start to finish.  We offer accounting, tax planning services, tax return preparation, business consulting, and U.S. and international company formation services.  Our professionals provide the highest quality services at  competitive rates.  But don't take our word for it, give us a call and let us prove what we can do for you. Read our Leading Media Articles, Customer Testimonials and learn more About Us.

Personal Consultations  You get answers to your specific questions by speaking directly to Hannah Terhune, an experienced hedge fund and international tax attorney.  Ms. Terhune's hard-earned knowledge and experience can be put to work to save you unnecessary steps and costly wasted effort.  The consult is an invaluable opportunity to speak to Hannah one-on-one, and learn how to achieve more in less time.  As a result, you can anticipate that the return on your investment will far outweigh the costs associated with our unsurpassed services.   Ms. Terhune's credentials reflect an invaluable resource that combines a well-informed professional practitioner with sound ethical judgment that cannot be over-estimated.  The expertise required to recommend best solutions and provide sound advice should never be taken lightly.  We are confident that when you are finished with your consultation, you will be impressed and more informed about your business plans than ever before. Call (307) 213-4732 or Click Here to Request Services.

Our Commitment 
Henry David Thoreau wrote:  "Do not hire a man who works for money, but him who does it for love of it."  We are committed to your business plans and bringing you the best possible options.  We are an established and internationally recognized business that serves and educates our clients throughout the industry.  We do this by striving for the best results.  Above all, we are a law firm.  A lawyer is a philosopher and role model.  The ability to improve our clients' lives is a privilege that we do not take lightly.  There is tremendous power in being able to effect a positive change in our clients' lives.  Our aim is to welcome our clients and to provide a comfortable, warm environment for all.  Thanks for visiting our website.  We hope to have the opportunity to serve you. 

Website content and design are copyrighted 2001-2012 © by Hannah M. Terhune and all rights are reserved.  This web site is designed for general information only.  The information presented at this site should not be construed to be formal legal advice nor the formation of an attorney/client relationship.  

Call (307) 213-4732 or Email hterhune@CapitalManagementServicesGroup.com