Seed Capital Incubator Funds, Incubator Fund In the USA &
Licensed Incubator Funds in Other Countries
Incubator Seed Capital Funds are for active traders & investors who want to start a hedge fund. Starting with an incubator seed capital fund can save you money upfront and is the least expensive way to start an investment advisory business. Our proprietary incubator seed capital fund model results ina performance record that is marketable legally in the fund's offering documents (written at a later time) and is less expensive to create than a traditional incubator hedge fund. Incubator funds are not a creature of statute in the USA.
Incubator Fund & Seed Capital Incubator FundThe USA does not have a licensed incubator fund statute as does numerous other countries published in the past 5 years. In the USA, the term "incubator fund" is slang for a basic hedge fund structure that does not take on outside investors for a period of time. It is a type of "lab rat" that -- should it runs the maze and survives the experiment -- goes on to live on and not die. The maze and experiment is you trading your money in the markets in real time, executing your proprietary trading strategies. Again, in the USA, the term is a colloquialism and has no legal meaning.
Starter Funds: Incubator Fund & Incubator Seed Capital Fund The key difference, aside from cost, between the two types of "starter hedge funds" is the source and method of funding. A seed capital incubator fund accepts only the sponsor monies. In such case, the seed capital incubator fund can be formed with one entity.
Caution: When the incubator seed capital fund is used, careful drafting of the fund's operating agreement is needed. It cannot be created with a short form boilerplate operating agreement found on the Internet. Actually with any starter fund, do not use a short form operating agreement for the fund or its general partner/manager/director.
Caution: If the sponsor resides in a USA community property state, an affidavit should be included in the incubator seed capital fund's operating agreement to negate that factor.
The traditional USA incubator fund is formed with two entities. If monies from "friends and family" are used to the incubator fund, you cannot charge performance and management fees to the investors. Any fund with USA investors other than the fund sponsor must file a Form D with the SEC and file Rule 506 state notices.
Caution: Regulation D cannot be avoided by claiming that the money invested in the fund is debt (i.e., a loan). The SEC has ruled on cases like that and guidance is found in "no action letters" issued by the SEC.
Licensed Incubator Funds It is necessary to note that many countries have a licensed incubator fund regime. With an offshore licensed incubator fund, investors are allowed and performance and management fees may be charged if the investment manager is licensed appropriately (or exempt from licensing). Some countries retained quietly an off books incubator fund structure.
The USA does not have a licensed incubator fund statute. In the USA, the term is a colloquialism and has no legal meaning.
A key difference between a full-fledge hedge fund and an incubator seed capital hedge fund is your ability to charge performance and management fees & availability of offering documents. Learn More About Hedge Fund Offering Documents You deposit your own money as “seed capital” into the hedge fund. While you can accept money from friends and family in your incubator seed capital hedge fund, you cannot charge them performance and management fees (in the USA). With an offshore incubator, fees may be charged in the investment manager is licensed or exempt from licensing. If your incubator seed capital fund has US investors, file a Form D with the SEC and Rule 506 state notices.
Can you prove your trading talent? If you are planning to start a fund you experienced success trading your own account. The main reason why active traders do not realize their dream of starting a fund is that they do not have a proven track record. Unless you are verified as a successful trader or investor, you will not have investors. You may verbal commitments to invest in your fund that do not materialize. You find your prospects were just being polite. For successful traders like you, this is annoying. Securities laws make it prohibitive to use your personal trading results to promote your new money management business. Our incubator seed capital hedge fund strategy is a proven solution to your lack of trading credentials. By setting up an incubator seed capital hedge fund and following our unique protocols, you will create a performance record that can be marketed to prospective investors and clients. When you are sure that investors will invest with you, we can quickly upgrade your incubator seed capital fund to a full blown hedge fund.
Have Proven Trading History? Do you or your incubator seed capital fund already have a solid trading history and good track record? When you work with us during the incubator seed capital fund development process, you gain access to a veteran hedge fund and tax attorney, Hannah Terhune. She and her staff carefully guide you through the process of setting up the incubator seed capital hedge fund. Hannah Terhune developed this strategy in 2005 (see archive.org) as a result of working closely with investors and traders. She understood that an answer was needed to deal with the biggest legal frustration for 'at home' traders: not being able to use personal prior trading results as proof of their ability to successfully trade the markets. Many "at home" start up funds succeed. Learn More About Hedge Fund Performance Reports
Start an Incubator Seed Capital Fund Unless you are an established professional trader, it is hard to attract investors to your fund (or spot forex fund, commodities pool, offshore fund, master feeder fund). For successful traders, this lack of pedigree is frustrating. Our incubator seed capital fund strategy is a solution to a trader's lack of industry credentials. By setting up an and following our protocols, you can create a marketable trading record, complete with a tear sheet to show to interested investors.
When you are confident that investors are ready to invest in your fund, we work quickly to prepare the offering documents (the most expensive part of setting up a hedge fund). If you already have investors waiting in the wings, you will want to skip the incubator seed capital fund strategy and set up the full fund. If you do not have investors lined up, our incubator seed capital fund strategy is compelling. Our incubator seed capital fund strategy gives you time to tune your business plan and learn about hedge fund operations and the money management business. Once your incubator seed capital fund is successful and you are ready to allow outside investors into the fund, it is time to create the fund's offering documents.
Hedge Fund Company On occasion, an incubator seed capital fund may be established with one company. However, a simple business entity cannot be used as a standalone incubator seed capital hedge fund as more than one share class is needed. Generally, you need to form two business entities: the hedge fund, and its investment manager. In the USA, the hedge fund company is typically set up as either a Delaware Limited Partnership (LP) or Limited Liability Company (LLC) in the USA or offshore. We can set up both USA companies for you quickly. Contact Us for Assistance
Why a Delaware Hedge Fund? In the United States, hedge funds are found chiefly in Delaware. U.S. hedge funds are established primarily in Delaware because Delaware offers the most advanced business friendly law in the United States. In fact, Delaware’s business friendly environment is attractive to companies across the globe, not just hedge funds. Governing law matters. Delaware corporate law affords directors and officers a great deal of discretion in managing the business free from the undue interference of shareholders and regulators. Delaware's highly regarded reputation stems from the Court of Chancery that focuses solely on company law. The Court of Chancery has earned a reputation for fairness and decisiveness when hearing disputes between investors and hedge fund managers. Indeed, the Delaware “brand” of company law has been "exported" to other countries. Moreover, Delaware is one of the most protective jurisdictions in the world of proprietary information. The issue of privacy extends beyond Delaware's borders to other U.S. states. Learn More About Delaware Company Law
Hedge Fund Management Company The hedge fund's general partner/management company can be formed in your home state or home country. However, there are good reasons for setting up the general partner/investment manager somewhere else. If you are not certain about your plans to stay in your home state or country, we suggest setting up a general partner/management company in Delaware. For tax reasons, hedge fund sponsors based in New York or Texas may consider setting up three companies: the hedge fund, the investment manager for the carried-interest share, and a management company.
Why the United States? Even if you are based in another country, consider forming your fund in the USA. The United States offers easy low-cost access to the legal, tax, accounting, retail and institutional brokerage, and the regulatory services needed by a hedge fund sponsor to organize a hedge fund. Despite what hedge fund sponsors think about the purported negativity surrounding the United States, more establish USA based hedge funds because of the minimal expenses associated with starting a USA hedge fund. Hedge fund sponsors (i.e., the organizer(s) of the hedge fund) based outside the United States are usually surprised to learn about the “light touch” of regulation and low costs associated with forming a hedge fund in the USA. Hedge fund sponsors (the organizers of the hedge fund) based offshore can set up both a hedge fund and its management company in the USA. For you, the USA is offshore. Learn More Here
The United States Allows Hedge Fund Advertising The JOBS Act, signed on April 5, 2012, lifted the ban on hedge fund advertising for hedge fund's operated by fund managers registered with either the SEC or a state regulator. The decades-old restriction on how hedge funds can raise money is gone! Hedge fund managers can speak publicly about their hedge fund's strategies and performance and advertise normal channels. The Securities & Exchange Commission (SEC) issued proposed hedge fund marketing rules. Learn More About Hedge Fund Advertising
Performance Reports We develop the performance audit results needed to attract investors to your hedge fund. You cannot rely on brokerage reports alone to prove your skills. A third party must verify and certify that your trading skills exist as well as create metric reports that demonstrate you are not a "one hit wonder" or a unicorn. Investors want consistency from month to month and year to year. The brokerage statements do not go that far in terms of presenting historical trading data. You need a tear sheet backed up by audited numbers and metrics.
Why an Incubator Seed Capital Fund? Market conditions have never been better for setting up a hedge fund. Investors prefer to have money managed on a personal basis and closer to home these days. Investors are trending away from the continuing cons on Wall Street and heading toward Main Street when looking for help with their portfolios. It is no secret that small and customized hedge funds have taken up residence on Main Street and are attracting investors in droves. Traders that only dreamed of making a living by managing money for others are turning those dreams into reality for themselves and so can creating a hedge fund to protect and manage your assets or the assets of others for a fee is a practical way to earn a living. Successful hedge funds continue to attract the wealthy, the working not-so-wealthy, businesses, and pension funds looking for better investment options. Despite recent law changes, the United States still offers a favorable environment for smaller hedge fund startups.
LEADING MEDIA CONTENT & ARTICLES ON HEDGE FUNDS & INTERNATIONAL TAX BY ATTORNEY HANNAH TERHUNE
Her articles are widely reprinted in various media and recommended by TheStreet.com. We would say "Contact Us for Reprint Rights" but our competitors take our content without our permission. Look at Internet Archive.Org. We plan to keep innovating!
Ms. Terhune's credentials reflect an invaluable resource that combines a well-informed professional practitioner with sound ethical judgment that Is unparalleled in the industry. The expertise required to recommend the best solutions and provide sound advice should never be taken lightly. When you are finished with your consultation, you will be both impressed and informed about your business plans. Contact Hannah Terhune now!
TO SPEAK TO HANNAH TERHUNE TODAY, BUY A CONSULTATION 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 utilized, as a tool, to save you unnecessary steps and costly wasted effort. The consultation 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.
LEADING MEDIA CONTENT & ARTICLES ON HEDGE FUNDS & INTERNATIONAL TAX BY ATTORNEY HANNAH TERHUNE
Her articles are widely reprinted in various media and recommended by TheStreet.com. We would say "Contact Us for Reprint Rights" but our competitors take our content without our permission. Look at Internet Archive.Org. We plan to keep innovating!
Ms. Terhune's credentials reflect an invaluable resource that combines a well-informed professional practitioner with sound ethical judgment that Is unparalleled in the industry. The expertise required to recommend the best solutions and provide sound advice should never be taken lightly. When you are finished with your consultation, you will be both impressed and informed about your business plans. Contact Hannah Terhune now!
TO SPEAK TO HANNAH TERHUNE TODAY, BUY A CONSULTATION 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 utilized, as a tool, to save you unnecessary steps and costly wasted effort. The consultation 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.
Fund Types There are different types of incubator seed capital hedge funds. An incubator seed capital hedge fund can be started for any specific trading strategy or asset class. It should mirror the investment program to be used in the future to trade customer money.
Cryptocurrency Funds (and funds holding utility tokens, security tokens. non-fungible tokens, real property, tangible property, art, blockchain assets, & tax liens) fall under regulation as equities or managed futures, or both in the USA. Offshore, there are designated sandbox regimes (bespoke laws) that apply to modern asset classes. The laws still apply even if the regulators have no idea about how the asset creates value or operates. The laws apply and are not arbitrary.
Equity Funds If the hedge fund trades securities, ETFs, etc., and has U.S. investors and charges performance and management fees, the hedge fund manager will have to register either with the SEC or its "home" state unless an exemption from investment adviser registration is available to it. Learn More About Investment Adviser Registration We offer SEC and state-level investment adviser registration services.
Spot Forex, Commodities & Managed Futures Funds If the hedge fund trades in one or more of the following: spot forex, managed futures or commodities, futures contracts, commodity options (including options on futures contracts), leverage contracts involving certain precious metals, futures contracts and commodity options traded on a board of trade, and/or foreign futures and foreign options and has U.S. investors and charges performance and management fees, then the hedge fund manager has to register with the National Futures Association (NFA), unless an exemption from registration is available. Incubator or seed capital hedge fund trading spot forex, managed futures and commodities can operate under NFA Rule 4.13(a)(1). We offer NFA registration services and a filing service for NFA exemptions. Recently, the NFA eliminated the exemption contained in Rule 4.13(a)(4)--a rule relied upon by a substantial portion of the hedge fund industry. Hedge fund managers operating commodity pools under Rule 4.13(a)(4) have until December 31, 2012 to register as commodity pool operators, unless they can avail themselves of some other exemption. Learn More About NFA Registration
How long do I have to operate an incubator or seed capital fund before marketing the fund to investors? The incubator or seed capital hedge fund assets are managed about 1 to 3 years. It is our experience that fund managers typically incubate their hedge funds for a short period of time and then convert the fund to a full-fledged hedge fund. The better the track record, the more attractive the investment will appear to prospective investors. If you have an audited trading history and if investors are ready to go, why wait? Set up the full-fledged hedge fund.
Can I have multiple incubator seed capital hedge funds? Yes.
Can I gather indications of interest from potential investors during the incubation phase? Yes. Performance information about the incubator seed capital hedge fund can be provided to preexisting and potential contacts at any point after the fund's inception. You can gather indications of interest through your personal network, friends and family (i.e., persons with whom you have a pre-existing relationship). Learn More About Attracting Investors
Hedge Fund Offering Documents Offering documents are the key to hedge fund sales. While there is no requirement that prospective investors with offering documents, it is common industry practice to do so. Most hedge funds provide written information to their investors in the form of a private offering memorandum (Memorandum). Offering documents-- referring to both the prospectus and subscription agreement--go by several names and/or acronyms including: Private Placement Memorandum, PPM, Offering Memorandum, OM, or Prospectus. Whatever it is called, offering documents are extensive documents individually created for each hedge fund. In the United States, offering documents include a private placement memorandum (PPM, OM or prospectus), a limited partner (or limited liability company) agreement, and a subscription agreement. If the hedge fund’s manager is registered with a U.S. federal or state regulator, the offering document “package” will included a Form ADV Part 2, which describes the investment manager in detail. Offering documents for an offshore hedge fund include the private placement memorandum and the subscription agreement. Learn More About Hedge Fund Offering Documents
The United States is a Safe-Haven for Business A 2006 Government Accountability Office report, found that most other states do not require ownership information when businesses are formed or don't have to submit periodic reports. Read the GAO 2006 Report of U.S. Company Formations In addition to Delaware, Nevada and Wyoming are advantageous places to set up a company. Learn More About USA Company Formations Given the depth, privacy, predictability and pro-business cast of Delaware's company law, it makes good business sense to set up a hedge fund in Delaware. Contact Us for Assistance
We offer company formation services, registered agent/registered office and virtual office services in Delaware. Learn More About Delaware Company Services Although a little more expensive to form and maintain, offshore incubator or seed capital hedge funds tend to be more flexible that those set up in the United States. Learn More About Offshore Funds and Offshore Incubator Seed Capital Funds U.S. Regulatory Matters Even though not necessary for an incubator or seed capital hedge fund, we will discuss with you NFA, SEC and state-level investment adviser registrations and licensing, as well as other matters you will address when you convert the incubator or seed capital fund to a full-fledge hedge fund. The foregoing issues are relevant if your fund accepts U.S. investors or if you base hedge fund management in the United States. Learn More About Investment Adviser Registration if you trade securities. Learn More About NFA Registration if you trade spot forex, commodities or managed futures.
How to Transition an Incubator Seed Capital Fund to a Full-Fledge Hedge Fund With the existing hedge fund and investment manager already in place and a marketable track record to show potential investors, converting your incubator seed capital hedge fund to a full-fledge hedge fund is a straightforward process. Once you are ready to launch the fund, you will need to prepare offering documents for the hedge fund. We prepare offering documents for a competitive price. Contact Us for Assistance
Should I Make a Mark-to-Market Election? Only someone who qualifies as an active securities trader can elect MTM treatment. Although the MTM election can be made in a year in which you qualify as an active trader, the MTM election once made applies to subsequent years whether or not you are an active trader in later years. Learn More About Mark-to-Market Election
Can I seed the incubator or seed capital fund with my IRA? Yes. Find a flexible IRA custodian. You will form a separate sole purpose LLC to facilitate your IRA's investment into your incubator seed capital fund. For the structure to be effective, you will move your IRA account to a financial custodian (e.g., you would roll over your IRA and other retirement/tax advantaged accounts to an IRA custodian) that allows alternative investments. If the alternative custodian you select is not also a broker, you would then set up a LLC and list the IRA account as the sole owner. If you use margin to trade, do not use your IRA as seed capital or set up an offshore incubator seed capital fund. The LLC is the self-directed IRA and be also be an investor in your new hedge fund, a separate entity. Once the LLC is funded with your existing IRA (the initial funding), you will not be able to add money from other sources to this LLC. The correct approach is complex and requires careful drafting of the operating agreement.
Caution: Brokers just want to sell structures that generate trades. Custodians are supposed to cautious. When you have an IRS problem because you set up your IRA LLC in a way that violates tax law following vague information from a broker, that broker will not help you. Contact Us so to avoid making any mistakes!
Can I operate more than one incubator seed capital fund? Yes. Some managers will incubate multiple funds in order to develop track records for different strategies.
How much money do I need to seed the incubator seed capital fund? There is no minimum investment amount. You are just trying to create a performance percentage based on real time trading.
Can I open a trading account for my incubator seed capital fund at any brokerage firm? Yes. As soon as the hedge fund is formed you can open a brokerage account and begin trading. We obtain the EIN (tax identification number) of the fund and draft any banking and brokerage resolutions you need at no extra cost to you. Whether your hedge fund is formed in the United States or offshore, you will need a U.S. tax identification number to open a U.S. bank or brokerage account.
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. After reading our many leading articles and web content, you will probably have questions for us. The best way to get quick answers to your specific questions is to speak directly to one of our leading attorneys. When you buy a 30 or 60 minute consultation, we contact you quickly to schedule. Most of our clients begin with a consultation by phone and then use email to follow up. 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.
How are offshore incubator seed capital funds taxed? Offshore incubator or seed capital hedge funds are generally set up as corporations in tax-free countries. A tax election can be made so that U.S. investors can treat their interest in an offshore corporate fund as a partnership interest for U.S. tax purposes. However, this is not recommended if the fund trades on margin and the U.S. investors are tax-exempt. Learn More About Hedge Fund Taxation
Should I set up an offshore incubator seed capital hedge fund? Outside the United States, the rules governing incubator or seed capital hedge funds are more relaxed; however the start-up costs are a bit higher. It also takes a little longer to set up an offshore incubator or seed capital hedge fund. In addition, when you are ready to convert an offshore incubator or seed capital hedge fund to a full-fledge hedge fund, you will find that it takes more time and mental effort to do so (due to foreign regulatory issues) than it does in the United States. Learn More About Offshore Hedge Funds A U.S. incubator or seed capital hedge fund can be converted to a full-fledge hedge fund in the United States very quickly. Learn More About Starting a Hedge Fund U.S. investors can invest in an offshore hedge fund. Foreign investors can invest in a U.S. hedge fund. A foreign investment manager can set up and run a U.S. hedge fund. A U.S. presence is not required.
Can I add or withdraw capital from an incubator seed capital hedge fund? Yes. The track record of the fund is measured as the percentage return of assets under management, regardless of the amount of capital contributed to or withdrawn from the fund. Learn More About Hedge Fund Performance Reports
Do I need an administrator during the incubator or seed capital fund period? No. You do not need to buy accounting services to start and run an incubator or seed capital fund. Postponing the need to hire an administrator is another advantage of establishing an incubator or seed capital fund. Administrators are helpful with the support of a full-fledged hedge fund (e.g., providing net asset value calculations, preparing monthly reports, and calculating fees). Learn More About Hedge Fund Administration, Taxes and Audit
How are U.S. Incubator or seed capital Hedge Funds Taxed? The U.S. incubator or seed capital fund is taxed as a pass-through entity for U.S. tax purposes. This means that the incubator or seed capital fund's realized gains and losses are taxed at the investor level. The tax character (i.e., ordinary income or capital gain treatment) of the gains and losses pass through to the investor level as well. Learn More About Hedge Fund Taxation
ARE YOU AFRAID OF WHAT YOU DO NOT KNOW? 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 utilized, as a tool, to save you unnecessary steps and costly wasted effort. The consultation 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 Is unparalleled in the industry. The expertise required to recommend the best solutions and provide sound advice should never be taken lightly. When you are finished with your consultation, you will be both impressed and informed about your business plans. Contact Hannah Terhune now!
We have both regulatory experience and the understanding of the foreign exchange and securities markets. 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.
WHY HIRE US? When you hire us for hedge fund you get a unique combination of securities, tax, and international experience, focused on the trader niche. We are one destination for 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 to and deliver quick turnaround times.
We understand that clients want to begin business as soon as possible. We conceive, structure, and deploy the best strategies. Our customers value our one-stop shop relationship. We help you start your business and continue to assist you. Our tax services affiliate handles accounting, software, and tax compliance, including all tax matters (tax planning and tax returns). Only one thing counts with us and that is our customer relationships!
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.
MEET ATTORNEY HANNAH M TERHUNE Hannah Terhune, a 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 of the industry. They are embraced worldwide as a definitive and reliable source of critical information. Contact Us for Articles & Reprint Rights
Strategic Hedge Fund Planning by Hannah Terhune. Wilmott Magazine Ltd. (Volume 2013, Issue 63, pages 8-11 January 2013).
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)
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)
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)
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)
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 U.S./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)
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)
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)
Using Stripped Subsidiaries for Foreign Country Sales Another Alternative to the Traditional Buy-Sell Model. Practical U.S./International Tax Strategies (July 31, 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)
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)
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.
Offering Exceptional Care for a Select Few Capital Management Services Group is a small law firm catering to active investors, active traders, day traders, investment advisers and hedge funds worldwide. We offer comprehensive legal, tax and accounting services. We also offer hedge fund development services, small business planning, wealth preservation and wealth management services, and asset protection services. Our goal is to offer exceptional care for a select few.
Concierge ServiceWe offer corporate “white glove” concierge service to select clients. We set up many types of funds, provide business advice and offer ongoing support to all clients. We try to help people as their needs evolve. Our best ideas are not on this website. Are you trying to develop a tax or regulatory footprint outside of your home country? We offer extended office services in Delaware and in other locations beyond the industry norm. We offer unique ideas and the bandwidth to implement them. We offer tax planning services, tax accounting, books and records preparation, and tax return filing services. If you have a business plan that is unique, know that countries offer “sandbox” regimes for businesses that do not fit into an existing regulatory framework.
24/7/365 ServiceYou may have an unusual situation that needs special attention. We are ready to 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 look forward to connecting with you personally and are confident that you will be impressed. We help our clients as their needs evolve and take pride in maintaining long term 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 bringing you the best possible options. We are an internationally recognized business serving clients while educating the industry. We do this by striving for the best results. We are a law firm and not a document chop shop. A lawyer is a philosopher and role model. The ability to improve client lives is a privilege that we do not take lightly. There is tremendous power in being able to effect a positive change in the world.
