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Meet Hannah Tribune
Offering Legal, Tax, Business & Banking Services to
Hedge Funds & Fund Managers
 Worldwide
Hedge Fund & Tax Articles We Wrote

Leading Media Content & Articles on Hedge Funds & International Tax Planning

Follow @HannahTerhune Read leading, cutting-edge articles on hedge funds and taxes by Hannah Terhune, hedge fund and international tax attorney. Her articles are widely published on the Internet and recommended by TheStreet.com and other respected media.
Meet Hannah M. Terhune Hannah Terhune, a leading hedge fund and international tax attorney, contributes her expertise, experience and thoughts to many digital content media and magazine repositories. Hannah Terhune's articles are widely circulated on the Internet and recommended by TheStreet.com and other respected media.  Hannah Terhune's articles will advance your knowledge and understanding. They are embraced worldwide as a definitive and reliable source of critical information.

Strategic Hedge Fund Planning by Hannah Terhune.  Wilmott Magazine Ltd. (Volume 2013, Issue 63, pages 8-11 January 2013).

Hedge Funds - Limited Partners' Right of Access After Parkcentral Global, L.P., v. Brown Investment Management, L.P. by Jim Brennan.   Cititrust Edge Magazine (4th Quarter 2012).

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 by EurekaHedge.com (October 2007).

Offshore Fund Taxation.  Hedge Fund Monthly by EurekaHedge.com (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 by EurekaHedge.com (October 2006).

Drafting Hedge Fund Performance Allocations.  Hedge Fund Monthly by EurekaHedge.com (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 Performance 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)

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)

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)


Capital Management Services Group, Inc. is an authority in the hedge fund industry. It is a forward thinking law firm focused on creating long-term collaborative relationships with a select group of clients interested in the same.  It strives to provide “high touch” service and perform a defined set of legal and other services with impeccable efficiency.  Our best ideas are not on this website. When you consult with us, you have access to a unique and desirable blend of professional experience. Give us the opportunity to put our knowledge and expertise to work for you. We provide high quality services at competitive rates. We offer “white glove” corporate concierge service to select clients.  Need to develop a tax and regulatory footprint outside of your home country? Give us a call and let us prove what we can do for you.  We offer virtual residence and virtual office services in Delaware, Florida and in other locations. We can assist with opening U.S. bank and brokerage accounts. We have many ideas and the resources to implement them. Get answers to your specific questions and purchase a consultation with a lawyer.  We look forward to connecting with you personally and are confident that you will be impressed. We set up a variety of investment funds, provide business and global tax advice, while offering continuous support services to our clients.  We help our clients as their needs evolve and take pride in maintaining relationships with our clients. The views expressed on this website are subject to change based upon new information, new technology, consideration of new perspectives and/or for no reason at all. This website exists for educational purposes and nothing on this website should be considered as legal advice.  Website content and design are copyrighted 2023© by Hannah M. Terhune and all rights are reserved.

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Capital Management Services Group, Inc. is an authority in the hedge fund industry. It is a forward-thinking law firm focused on creating long-term collaborative relationships with a select group of clients interested in the same. It strives to provide “high touch” service and perform a defined set of legal and other services with impeccable efficiency. We offer professional tax advice, state and federal SEC advice, business planning services, international tax, and tax return preparation.

We cater to high-net worth individuals and businesses in the alternative investment community. We are experienced in wealth management, U.S. and offshore hedge fund formations, incubator hedge funds, spot forex funds, master/feeder funds, commodity pools, commodity trading advisory businesses, investment advisory companies, fund administration, SEC and state investment adviser registrations, compliance with Blue Sky laws, and hedge fund taxation. We offer professional tax advice, state and federal SEC advice, business planning services, international tax, and tax return preparation. You may have an unusual situation that needs special attention. We are ready to help. Perhaps you need extra support in an area, such as year-end accounting or performance audits. Blue-sky filings or Investment Advisor Registration We can help. We offer complete 24/7 access and great working relationships. We are simply second to none. Think outside the ordinary.

Our best ideas are not on this website. When you consult with us, you have access to a unique and desirable blend of personalized,yet, professional experience. Give us the opportunity to put our knowledge and expertise to work for you. We provide high quality services at competitive rates. We offer “white glove” corporate concierge services. We have many ideas and the resources to implement them. Get answers to your specific questions and purchase a consultation with a lawyer. We look forward to connecting with you personally and are confident that you will be impressed. We set up a variety of investment funds, provide business and global tax advice, while offering continuous support services to our clients. We help our clients as their needs evolve and take pride in maintaining relationships with our clients.

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. The views expressed on this website are subject to change based upon new information, new technology, consideration of new perspectives and/or for no reason at all. This website exists for educational purposes and nothing on this website should be considered as legal advice. Website content and design are copyrighted 2024© by Hannah M. Terhune and all rights are reserved.