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Electing Mark-to-Market Tax Treatment in the United States Section 475(f) of the tax code allows an active securities trader to treat all securities as: generating ordinary income or loss, and if held at year-end, marked to market (treated as sold for fair market value on 12/31 and then repurchased at that value on 1/1). Mark-to-market refers to the procedure followed at year end when all open positions are marked to market value. In effect a sale of all open positions (long and short) is triggered for tax purposes at year end using the year end market prices. On the first day of the following year those positions are bought back for the same market value. his tax treatment flushes out all realized and unrealized gains and losses for U.S. tax reporting purposes. An active trader may elect MTM for trading gains and losses and use the accrual or cash method of accounting for business expenses. Learn More About Traders in Securities and Trader Taxes
Should I Consider a MTM 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.
Before Electing Mark-to-Market Tax Treatment The decision making process is influenced by the fact that this election is a permanent election that can be revoked only with the consent of the IRS. However you could still establish an investment securities account or an investment company whose positions are outside the scope of the election. Trades in these other accounts generate capital gain or loss. Futures contracts (such as most index options) in mark-to-market accounts are still entitled to special tax treatment. MTM is not a preferred accounting method for profitable commodities and futures traders as the default tax rates favor them: 60% long term and 40% short term capital gain. The current maximum blended tax rate on commodities and futures is 23% versus 35% on securities. Electing MTM converts commodities and futures trading capital gains and losses (60/40 treatment) to ordinary gain and loss treatment (a 12% tax rate increase). But if you have large commodity trading losses before April 15 of the current year, electing MTM will allow the losses to be treated as ordinary.
Some Strategies for Making the Election 1. As the election is specific to the active trader, it is best made by an entity, rather than an individual taxpayer. An S corporation is easier to liquidate than an individual. The individual unhappy with his or her election needs to cease trading activities and become inactive (trading in the interim should be conducted through an entity) so that trading status lapses.
2. Make sure you (or your entity) are an active securities trader. There is no bright line test for trader versus investor status based on what little legal precedent exist. Make sure you have significant portfolio turnover on an annualized basis. Other factors (use of a margin account, options, futures, and short selling) can support active trader status.
3. The election for an active trader must be made by the original due date of his tax return for the current year with no exceptions. For a new trading entity, you must elect within 75 days of the start of trading activities, and then include the election in the entity's first tax return.
4. If your mix of positions includes both active trading and buying some positions (or taking some shorts), for the longer term you should establish an investment securities account. This account can be at the same brokerage where your active trading account is maintained.
Compensation Planning A manager of the offshore fund should ensure that his contracts are prepared so as to allow deferral of management and incentive fees. Through the use of properly prepared fund documents and the use of outside directors, a fund manager will be to defer for tax purposes substantial amounts of money (e.g., both the deferred fees and earnings on the fees compounded tax free in the fund).
Need Help? Consultations with veteran fund and international tax attorney Hannah Terhune allow you to customize your legal, regulatory, business and tax plans. She will discuss business development, tax, accounting, reporting and business strategies that will help you with your fund formation. Her focus is your long-term success; not selling you services you don't need. Talk to us at the earliest stages of your plans to avoid wasted time and money. Our focus on tax and securities law, assists with start-ups, incubators, small hedge funds and family offices, as well as establishing investment advisors. All of our legal work incorporates tax services and planning, with individualized tax, legal services and solutions to meet your needs. We do not sell or support canned business plans like our competitors. We offer the best value in the industry, some of the lowest prices in the world, outstanding support and customer service,no-obligation consults and free web and media content so that you can make informed decisions. You can purchase a 30 or 60 minute consultation or by calling the office at (307) 213-4732.
International Taxes Hedge funds should be aware of possible international filings if either they own an interest in a foreign entity or have an investor who is a non-U.S. taxpayer. Non-compliance with international tax filings could result in significant penalties. For example, a penalty for late filing of a return could be as high as 25% of the unpaid tax. In addition, FATCA requires non-U.S. financial institutions and non-U.S. entities (including offshore investment funds) to provide information to the IRS identifying U.S. persons invested in non-U.S. bank and securities accounts. The legislation is motivated by incidents of U.S. persons failing to report foreign-source income for U.S. income tax purposes. A 30% withholding tax applies on any "withholdable payment” made to a foreign financial institution (FFI) unless the FFI agrees with the IRS to take a number of specific steps pursuant to an FFI agreement. The specific steps are designed to ensure that U.S. persons are identified and U.S. tax is imposed on their investment income.
Offshore Hedge Funds Offshore funds are organized as corporations or trusts for marketing, tax, and legal reasons. If U.S. investors invest in or effectively control an offshore fund, complex U.S. tax rules (and complicated U.S. filing requirements) are operable (e.g., controlled foreign corporations, foreign personal holding companies, and passive foreign investment companies (PFIC) and need attention. Although an offshore fund generally does not have state tax issues, some states require partnerships to file state partnership tax returns if they have partners that are state residents. This could result in an offshore fund (e.g., one with a check-the-box election in effect and a New York feeder hedge fund as an investor) being required to file a state tax return even if it has no U.S.-source income and no ECI. Some of the issues are manageable, others are not and the offshore fund may be better off skipping or significantly limiting the presence of U.S. investors. Learn More About Offshore Hedge Funds
U.S. tax-exempt investors prefer offshore funds because of tax considerations. Under U.S. law a tax-exempt investor (such as an IRA, an ERISA-type retirement plan, a foundation, or an endowment) is liable for income tax on "unrelated business taxable income" (UBTI or UBIT) notwithstanding its tax-exempt status. This tax exposure exists when a U.S. tax-exempt investor invests in a fund that trades on margin. In those cases where complete investor confidentiality and privacy are necessary, an offshore fund should not accept any U.S. investors (tax-exempt or otherwise) and the fund manager should not be located in the United States.
Master Hedge Funds A master fund allows a fund manager to manage money for a broad spectrum of investors. The master fund is organized as an offshore corporation or trust (but can be taxed as a partnership only for U.S. tax purposes via a check-the-box election filed on Form 8832). A fund manager can pool money from country-specific feeder funds in the master fund. Trading gains are allocated to the feeder funds based on the percentage of assets under management.
International Traders Many international traders own U.S.-brokerage accounts and wonder if they will owe U.S. taxes. When a nonresident trader has a U.S. brokerage account, only interest and dividends earnings are subject to U.S. withholding tax. No U.S. withholding tax should apply to capital gains. Many brokerages will withhold taxes anyway. Nonresidents (individual or business) can file for a tax refund using a Form 1040NR and then properly structure their U.S. focused trading to prevent mistakes in the future. In most cases, U.S. tax liability does not arise. However, ownership in a "landed" U.S. business activity can trigger a U.S. tax bill and filing. If a nonresident trader owns a U.S.-brokerage account and spends more than 183 days in the United States (meeting either U.S. substantial presence test), U.S. source net capital gains are subject to U.S. tax. Most U.S. tax treaties contain provisions that reduce or eliminate tax on capital gains. The trader could also make a mark-to-market election for the trading activity to be taxed at lower rates. Being part of a U.S. proprietary trading firm business on a K-1 or W-2 basis triggers exposure to U.S. taxation.
U.S. Taxes The United States taxes citizens, businesses and residents on worldwide income. It also taxes nonresident individuals (meaning no green card or long-term U.S. presence) and businesses on U.S. source income at tiered rates based on net taxable income. Most other U.S. source income is taxed at a flat 30% rate through payer withholding. Withholding taxes often are reduced or eliminated in the case of payments to residents of countries with which the U.S. has an income tax treaty. In addition, certain statutory exemptions from withholding taxes are provided. Income of a non-resident alien individual or foreign corporation that is effectively connected with the conduct of a trade or business in the United States is subject to tax at the normal graduated rates based on net taxable income.
Deductions are allowed in computing effectively connected taxable income (ECI). Withholding taxes often are reduced or eliminated in the case of payments to residents of countries with which the U.S. has an income tax treaty. In addition, certain statutory exemptions from withholding taxes are provided. U.S. source non-ECI connected capital gains of non-resident alien individuals and foreign corporations generally are exempt from U.S. tax, with two exceptions: (1) gains realized by a non-resident alien individual who is present in the U.S. for at least 183 days during the taxable year, and (2) certain gains from the disposition of interests in U.S. real estate. The source of income received by non-resident alien individuals and foreign corporations is determined under rules contained in the Internal Revenue Code (Code). Interest and dividends paid by a U.S. citizen or resident or by a U.S. corporation generally are considered U.S. source income.
Taxation of the Limited Liability Company (LLC) One benefit of the use of limited liability company is the flexibility of being able to choose how the entity is taxed. There are many factors to consider when deciding to have your LLC taxed. Your choice should be based on your own specific situation. Therefore, before making any decisions on your form of business, you should speak with us. The single-member LLC provides corporate-level liability protection for the business owner along with taxation as a sole proprietorship. The LLC, like the corporation, is formed at the state level. Thus, state law makes the rules and can create the tipping point between making the LLC your choice of entity or not. For federal income tax purposes, the single-member LLC is a disregarded entity, meaning that it is disregarded as an entity separate from its owner. Disregarded entity status is what makes the single-member LLC a sole proprietorship for federal income tax purposes.
Single Member LLC (SMLLC) By default, an LLC is treated as a pass-through entity, which means that it does not pay U.S. tax directly, but its income or loss is allocated to the owners, who then pay taxes on that income. If the LLC has one member, it files no tax return and the transactions of the LLC are treated as transactions of the owner for tax purposes. In effect, it is disregarded for U.S. tax purposes. A single member LLC is treated as though it does not exist for tax purposes and thus the owner is treated as if he were running a sole proprietorship. All transactions (income and expenses) are included on the owner's U.S. tax return. Therefore, no separate tax return need be filed for the LLC. The owner of a SMLLC pays self-employment taxes on Schedule C income, just like a sole proprietorship.
For tax years after 2008, the IRS classified single-member LLCs as proprietorships for income tax purposes and corporations for payroll tax purposes. Before 2009, single-member LLCs were disregarded for both income and payroll tax purposes. Effective November 1, 2011, the IRS retroactively changed the rule to allow proprietorship treatment for family employment on or after January 1, 2009. This favorable retroactive treatment is also prospective, but it expires on or before October 31, 2014. The good news is that the IRS allows retroactive and prospective disregarded entity status to the single-member LLC for family employment purposes. The IRS has an "on or before October 31, 2014" expiration date for its change in the single-member LLC employment rules. This on-or-before date is a concern that you need to factor into your planning.
SMLLC Benefits Federal law currently taxes the single-member LLC as a proprietorship for both income and family employment tax purposes. Example. Say you set up a new single-member LLC to conduct what was previously your sole proprietorship business. As far as the IRS is concerned, nothing has changed; the IRS ignores the existence of your single-member LLC (it's disregarded) and continues to consider your business a sole proprietorship for federal tax purposes. Therefore, you report your business income and expenses on Schedule C, compute your self-employment tax on Schedule SE, and make quarterly estimated tax payments as usual.
The second benefit to the single-member LLC is the ability to use proprietorship (Schedule C) tax breaks, such as hiring your spouse to create a business tax deduction for a Section 105 medical reimbursement plan that pays the family medical expenses (health insurance, co-pays, out-of-pocket, and more); hiring your children without payroll taxes because they are under age 18 and working for a parent (disregarded entity); deducting interest paid on car loans;avoiding the cost of extra tax returns; and avoiding unexpected tax problems caused by self-dealing (although to ensure legal protection, you should avoid self-dealing).
Unlike an S Corporation (see below), a SMLLC is allowed good tax breaks, such as hiring your spouse to create a business tax deduction for a Section 105 medical reimbursement plan that pays the family medical expenses (health insurance, co-pays, out-of-pocket, and more). While no deduction is allowed for the cost of a disability insurance for an owner, the benefits are not taxed to the owner. Section 179 expensing flows through to the individual level.
SMLLC Cautions If you select the single-member LLC as your choice of entity, you pay self-employment taxes as a sole proprietor. For 2012, the self-employment tax is 15.3 percent on the first $110,100 of self-employment earnings and 2.9 percent on earnings above that. You need to factor the self-employment tax into a bottom-line comparison of which entity produces the best after-tax return. For example, with a switch from the SMLLC to an S corporation, you might reduce your self-employment taxes, but that benefit would cost you the single-member LLC deductions for the Section 105 medical reimbursement plan (see below).
Multi Member LLC (MMLLC) If the LLC has more than one member, the LLC can opt for treatment as a partnership for U.S. tax purposes. Income and losses of the LLC are allocated to the owners, who pay taxes on that income regardless of the amount of cash they received from the company. A distribution of cash to owners is itself a tax-free event. The owners of the LLC can be compensated for service to the company (called "guaranteed payments") in which case the payments are treated as an expense to the partnership and income to the owner. Subchapter K is quite flexible, and allows the owners to allocate the income between themselves in a variety of ways, sometimes in quite complex formulas (subject to certain limited restrictions in the Internal Revenue Code). When using a partnership tax approach, the income of the partners is generally subject to the self-employment tax.
Corporate Tax Option The owner(s) of an LLC, whether the LLC has a single member or multiple members, may choose to have their LLC taxed as a corporation. In this case, the LLC can be taxed as a C Corporation (or, if the owners are U.S. persons, an S Corporation). The ability of LLC owners to elect the LLC's method is called "checking the box" via filing Form 8832.
U.S. Regular Corporation Tax If an LLC elects to be taxed as a regular ("C") corporation, it is treated for tax purposes, as if it were a corporation. The company must file a corporate tax return (regardless of whether there is one member or multiple members) and the LLC itself pays taxes. Any income that is paid to owners in the form of dividends is also taxable income to the owner (resulting in double taxation), though taxed to the owner at the capital gains rate. An C Corporation pays FICA, Medicare, and unemployment taxes on wages paid to the owner. The owner-employee pays FICA and Medicare on the owner's wages. Active owners are considered employees of the company and can also be paid for their services to the LLC in the form of a salary or other payments. In that case, the payment is deductible. Note that wages paid to an under-age-18 child are subject to FICA, Medicare, and unemployment taxes.
Unlike an S Corporation (see below), a C Corporation is allowed good tax breaks, such as hiring your spouse to create a business tax deduction for a Section 105 medical reimbursement plan that pays the family medical expenses (health insurance, co-pays, out-of-pocket, and more). A deduction is allowed for the cost of a disability insurance for an owner (if the benefits are taxable to the owner) and Section 179 expensing.
As a result of the exposure to double taxation, many C Corporation owners pay themselves a salary or bonus. Such income is deductible to the corporation, as long as it is "reasonable." If the IRS determines otherwise, it can reclassify part of the salary as a constructive dividend and charge the company additional tax (and assert penalties).
S Corporation Tax for U.S. Persons Only If an LLC elects Subchapter S, it is treated for federal tax purposes, as if it were a corporation that elected to be treated as an S Corporation. Many form S corporations with no idea of the bottom-line results. In this case, the LLC files a corporate tax return but does not itself pay taxes. The income flows through to the individual level (caution: some states assess a corporate tax on the S corporation). Each owner is allocated a portion of profits or losses based on the percentage interest that they each own. As in a partnership, the owners must then pay the taxes themselves, regardless of whether any cash has been distributed to them. Any cash payments to owners (called distributions or dividends) are tax-free.
An S Corporation pays FICA, Medicare, and unemployment taxes on wages paid to the owner. The owner-employee pays FICA and Medicare on the owner's wages. Active owners are considered employees of the company and can also be paid for their services to the LLC in the form of a salary or other payments. In that case, the payment is deductible. Note that wages paid to an under-age-18 child are subject to FICA, Medicare, and unemployment taxes.
S Corporation Cautions The benefit of S Corporation status is that income that is not paid out as a salary is not subject to self-employment taxes. However, the IRS scrutinizes the salaries paid to owners and may decide that the owners are underpaid. If it does, the IRS may reclassify some of the LLC's income as wages, subjecting the LLC and the owners to additional payroll taxes and potential penalties.
Another caution to use of S Corporations is the limited ability to use proprietorship (Schedule C) tax breaks, such as hiring your spouse to create a business tax deduction for a Section 105 medical reimbursement plan that pays the family medical expenses (health insurance, co-pays, out-of-pocket, and more). You cannot make a Section 105 medical reimbursement plan available to more than 2% owners or their spouses. While no deduction is allowed for the cost of a disability insurance for an owner, the benefits are not taxed to the owner. Section 179 expensing flows through to the individual level.
Another disadvantage to using Subchapter S is that the designation is conditional. There are a number of requirements the company must adhere to (such as having only one class of stock). If the company fails to adhere to these requirements, it will automatically be converted to C Corporation status and face double taxation.
The single class of stock requirement is especially easy to violate inadvertently. If the LLC gives any owners preferred distributions or distributes distributions in any way except through a straight pro rata method, it could be deemed as having more than one class of stock. In addition, many of the default provisions in LLC statutes violate the single class of stock requirement, which means that the operating agreement of an LLC taxed under Subchapter S must be carefully written to override the default provisions.
Conclusion You are unlikely to identify a business entity that has all advantages for you and no disadvantages.
Offshore Unrelated Business Taxable Income (UBTI) Blocker Companies Many hedge funds use corporations as unrelated business taxable income (UBTI) blockers for their investors to facilitate hedge fund investment. UBTI blocker companies are used to prevent U.S. tax-exempt organizations from recognizing UBTI and to prevent foreign investors from recognizing income that is effectively connected to a U.S. trade or business, and therefore taxable in the United States. Hannah Terhune, a leading tax attorney, can help you with international tax planning and has published many international tax articles of interest to hedge fund managers. Contact Us
U.S. Tax Exempt Investors One reason to setup an offshore fund is so the fund can accept U.S. tax-exempt investors. Under the U.S. income tax laws, a tax exempt organization (such as an ERISA plan, a foundation, an endowment, etc.) engaging in an investment strategy that involves borrowing money (margin) is liable for a tax on “unrelated business taxable income” (UBTI). This is true even though the investor is otherwise tax exempt.
As U.S. funds are formed through pass-through entities (such as the limited partnership or limited liability company) the UBTI activity passes through the fund to the tax exempt investor, thereby creating the UBTI tax issue. U.S. taxable investors don't care because they need to pay tax in any event. However, U.S. tax-exempt investors are quite concerned. The UBTI tax can be avoided by arranging for the tax-exempt entity to invest in an offshore fund formed as a corporation. The UBTI gets blocked, so to speak, at the wall of the corporation.
This is not an easy tax issue to grasp. UBTI is income from regularly carrying on a trade or business that is not substantially related to the organization's exempt purpose. UBTI excludes various types of income such as dividends, interest, royalties, rents from real property (and incidental rent from personal property), and gains from the disposition of capital assets unless the income is from debt-financed property. Using margin to trade creates debt financed property. As a fund's income attributable to the use of margin may constitute UBTI to them, tax-exempt investors generally refrain from investing in funds classified as partnerships using leveraged trading strategies. As a result, fund sponsors organize separate offshore funds for tax-exempt investors.
Offshore Unrelated Business Taxable Income (UBTI) Blocker Companies Many hedge funds use corporations as unrelated business taxable income (UBTI) blockers for their investors to facilitate hedge fund investment. UBTI blocker companies are used to prevent U.S. tax-exempt organizations from recognizing UBTI and to prevent foreign investors from recognizing income that is effectively connected to a U.S. trade or business, and therefore taxable in the United States. Hannah Terhune, a leading tax attorney, can help you with international tax planning and has published many international tax articles of interest to hedge fund managers. Contact Us
International Taxes Hedge funds should be aware of possible international filings if either they own an interest in a foreign entity or have an investor who is a non-U.S. taxpayer. Non-compliance with international tax filings could result in significant penalties. For example, a penalty for late filing of a return could be as high as 25% of the unpaid tax.
Foreign Account Tax Compliance Act, or FATCA The U.S. Treasury proposed regulations for implementing the Foreign Account Tax Compliance Act, or FATCA. FATCA requires foreign financial institutions (FFI) and U.S. holding agents to track U.S. account holders. Basically, foreign banks, brokers, custodians and offshore hedge funds--all are classified as an FFI.
Under FATCA, FFIs are required to disclose details about their U.S. and certain foreign clients to the IRS annually. The new law takes effect on January 1, 2013. This translates to reporting to the U.S. Internal Revenue Service on U.S. accounts beginning in 2014 (for the 2013 calendar year) and withholding on certain types of payments beginning January 1, 2014.
Beginning in 2014, hedge funds must report information regarding their investors that are "U.S. accounts." Offshore hedge funds have to collect, verify, manage U.S. account holder tax data, and be able to handle U.S. tax reporting and withholding responsibilities by 2017.
Any U.S. individual or entity unwilling to provide the required information faces 30% tax on amounts that are deemed attributable to its share of the underlying income and gross proceeds from the fund’s direct and indirect U.S. assets. For offshore hedge funds, this rule starts in 2017.
International Traders Many international traders own U.S.-brokerage accounts and wonder if they will owe U.S. taxes. When a nonresident trader has a U.S. brokerage account, only interest and dividends earnings are subject to U.S. withholding tax. No U.S. withholding tax should apply to capital gains. Many brokerages will withhold taxes anyway. Nonresidents (individual or business) can file for a tax refund using a Form 1040NR and then properly structure their U.S. focused trading to prevent mistakes in the future. In most cases, U.S. tax liability does not arise. However, ownership in a "landed" U.S. business activity can trigger a U.S. tax bill and filing. If a nonresident trader owns a U.S.-brokerage account and spends more than 183 days in the United States (meeting either U.S. substantial presence test), U.S. source net capital gains are subject to U.S. tax. Most U.S. tax treaties contain provisions that reduce or eliminate tax on capital gains. The trader could also make a mark-to-market election for the trading activity to be taxed at lower rates. Being part of a U.S. proprietary trading firm business on a K-1 or W-2 basis triggers exposure to U.S. taxation.
U.S. Taxes The United States taxes citizens, businesses and residents on worldwide income. It also taxes nonresident individuals (meaning no green card or long-term U.S. presence) and businesses on U.S. source income at tiered rates based on net taxable income. Most other U.S. source income is taxed at a flat 30% rate through payer withholding. Withholding taxes often are reduced or eliminated in the case of payments to residents of countries with which the U.S. has an income tax treaty. In addition, certain statutory exemptions from withholding taxes are provided. Income of a non-resident alien individual or foreign corporation that is effectively connected with the conduct of a trade or business in the United States is subject to tax at the normal graduated rates based on net taxable income.
Deductions are allowed in computing effectively connected taxable income (ECI). Withholding taxes often are reduced or eliminated in the case of payments to residents of countries with which the U.S. has an income tax treaty. In addition, certain statutory exemptions from withholding taxes are provided. U.S. source non-ECI connected capital gains of non-resident alien individuals and foreign corporations generally are exempt from U.S. tax, with two exceptions: (1) gains realized by a non-resident alien individual who is present in the U.S. for at least 183 days during the taxable year, and (2) certain gains from the disposition of interests in U.S. real estate. The source of income received by non-resident alien individuals and foreign corporations is determined under rules contained in the Internal Revenue Code (Code). Interest and dividends paid by a U.S. citizen or resident or by a U.S. corporation generally are considered U.S. source income.
U.S. Individual Investors U.S. taxable investors in an offshore fund structured as a corporation may be exposed to onerous tax rules applicable to controlled foreign corporations, foreign personal holding companies, or a passive foreign investment companies (PFIC). To attract U.S. individual investors, fund sponsors of an offshore fund or offshore master fund should elect to have it treated as a partnership (for U.S. tax purposes only) so that these U.S. investors avoid harsh tax rules. Under the U.S. entity classification rules (i.e., check-the-box) an offshore fund elects to be treated as a partnership for U.S. tax purposes by filing Form 8832, "Entity Classification Election."
U.S. State Taxes Although offshore funds generally do not have nexus to the states, many states still require partnerships to file state partnership tax returns if they have partners that are residents of their jurisdiction. This could result in an offshore fund with U.S. partnership tax status being required to file a state tax return even though it arguably may not be required to file a Form 1065 since the partnership has no U.S. income. Such state and local partnership returns may require the identity of all partners (including foreign partners) to be included as part of the return. An offshore fund electing partnership status should carefully analyze the connection of its activities to the United States and the residencies of its U.S. investors to determine federal and state filing requirements as well as provide proper disclosure as to these filing obligations to its foreign investors.
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