OFFERING TURNKEY LEGAL & BUSINESS SERVICES & SOLUTIONS FOR HEDGE FUNDS & INVESTMENT MANAGERS WORLDWIDE
STARTING A HEDGE FUND & INVESTMENT MANAGER
Starting 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. We are on the cutting edge of hedge fund development, launch and operations. We invite you to share your dreams with us and allow us to tell you exactly what you may need up front. You may need one or all of the following: incubator fund ("startup fund"), tax planning advice, Federal, State and/or British Virgin Islands investment adviser registration, blue sky filings, tax filings, a launch audit of seed capital, tax return preparation services, and access to low cost annual fund performance audits.
It is important to plan for tax and regulatory considerations as you develop your plans to launch a hedge fund. This allows you time to develop a track record that will be useful when you are ready to attract investors to the fund. We stay involved with you throughout the development process. We provide all these services at a very low costs. Read what our clients have to say about us and read our numerous articles published in the media worldwide. Successful hedge funds continue to attract the wealthy, the working not-so-wealthy, businesses, and pension funds looking for better investment options worldwide.
The United States offers a favorable environment for smaller hedge fund startups. If you are interested in starting a hedge fund, contact us for a Free Consult with a hedge fund attorney. We set up hedge funds both in the United States and in most other countries. The global hedge fund business offers great potential in the years ahead.
We offer all the services you need to start a hedge fund and our prices are among the lowest you can find worldwide. We work very closely with you throughout the hedge fund development process. There is a lot of data for you to process to get your fund setup properly. We make that as easy as possible for you by sending you a terms sheet that defines most of the sections in our standard documents that change from fund-to fund. We review this data and consult with you regarding your choices and any issues we identify, or questions that you may have, and develop the first draft of your documents. We draft the private placement memorandums, limited partnership agreements,subscription agreement, and resolutions. As we refine your choices and finalize certain information, we generate additional drafts for your review. We understand your needs better than anyone else and our products and services were developed to meet the needs of day traders and new fund mangers. We help you set up quickly. In many cases, industry compliant hedge funds can be developed and launched in three weeks or less.
Managed Account First Strategy It costs more money to set up a hedge fund and the process takes a little longer. If you have customers ready, willing and able to commit money now, start by setting up a managed account business and add a hedge fund later. With a managed account business, you do not have to hire an auditor and an administrator. Your customers will open trading accounts at the broker you direct them to and you will manage their accounts pursuant to the managed account agreement you ask them to read and sign before committing to you and your trading program.
Time Needed to Form a Hedge Fund?The amount of time needed to set up a fund depends on your particular circumstances because no two funds (including the people who want to start them) are completely alike. In the United States, companies can be formed in a matter of just a few minutes. For example, in the State of Florida, a company can be formed over the Internet in less than ten minutes for about $120 USD. In the United States, no minimal capital is needed to form a company. Even a U.S. tax identification number (i.e., EIN or "employer identification number") can be obtained from the U.S. Internal Revenue Service over the Internet. In general, and assuming no registration is required, the average U.S. hedge fund takes about four (4) weeks to organize and launch, including the time needed to prepare offering documents and to arrange for the hedge fund's bank and brokerage accounts. Learn More About Hedge Fund Offering Documents Starting a hedge fund? Contact Us for a Free Fee Quote & Consultation
How many investors can invest in a U.S. hedge fund? If you set up a U.S. hedge fund you have two choices. If all of your investors, without exception, are “qualified purchasers,” your U.S. hedge fund can accept up to 500 investors. This type of hedge fund is referred to as a "3(c)(7) fund". "Qualified purchasers" are generally those that have $5 million in net investment assets. Once a 3(c)(7) fund reaches 500 investors, it may be required to register under the Securities Exchange Act of 1934. Learn More About Hedge Fund Regulation
If you are not able to satisfy the qualified purchasers only requirement, your U.S. hedge fund will have to operate on a smaller scale; one that can accept up to 100 investors. This type is of hedge fund is referred to as a "3(c)(1) fund". Of the 100 investors it can accept, only 35 can be non-accredited investors. Learn More About Accredited Investors While Section 3(c) of the Investment Company Act of 1940 provides exemptions from registration, it does not negate the need to file a Form D with the U.S. Securities Exchange Commission (SEC) for the hedge fund and state blue sky filings. Learn More About Hedge Fund Law and Learn More About SEC Form D & State Blue Sky Hedge Fund Filings Additionally, operating under one of the Investment Company Act exemptions does not negate the need of the hedge fund's manager to register as an investment adviser.
Equity Funds If the hedge fund trades securities, ETFs, etc., and has U.S. investors, 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 British Virgin Island, U.S. SEC and State-level investment adviser registration services. Contact Us for Assistance
Spot Forex, Commodities & Managed Futures Funds If your hedge fund trades 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, you must register with the National Futures Association (NFA), unless an exemption from registration is available. We offer NFA registration services and a filing service for NFA exemptions. Contact Us for Assistance 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) had until December 31, 2012 to register as commodity pool operators (unless availed themselves of some other exemption). Learn More About NFA Registration
U.S. Regulatory Filings, Form D & Blue Sky The sale of any hedge fund interest to any U.S. investor triggers federal and state-level reporting requirements for the hedge fund. A timely Form D must be filed with the U.S. Securities Exchange Commission (SEC) . This is the case even if the hedge fund is formed outside the United States. Both the SEC and state-level filings for the hedge fund are referred to as “blue sky” filings. The blue sky filing requirements confuse many. Blue sky filings have nothing to do with whether the hedge fund’s manager is required to be registered as an investment adviser. The most important thing to understand is that the requirement to file blue sky filings is triggered by the hedge fund’s sale of an interest to a U.S. investor. Many hedge fund managers wrongly believe (or are wrongly advised by brokers) that simply because they are exempt from registration as an investment manager , the hedge fund they operate is not required to file blue sky. That simply is not the case. Again, blue sky filings have to do with an investor’s subscription to a hedge fund interest. Blue sky filings have no bearing on whether the hedge fund's manager is, or should be, registered with a regulator. Many U.S. states require that a copy of the SEC filed Form D be provided to the state along with the states’ filing fee. The blue sky filing requirements and filing fees vary from state to state. Moreover, some states require that the hedge fund file blue sky filing on an annual basis (i.e., Alaska). Learn More About SEC Form D and Blue Sky Filings We offer SEC Form D filing services and state-level blue sky services for a reasonable fee. The SEC and state blue sky filings apply to any hedge fund that accepts U.S. investors even if the hedge fund trades spot forex, managed futures or commodities and without respect to whether the hedge fund manager is required to be registered with the U.S. National Futures Association (NFA). We offer SEC Form D filing services and state-level blue sky services for a reasonable fee. Contact us Assistance
Hedge Fund Offering Documents are the key to hedge fund sales. While there is no requirement that prospective investors in a U.S. hedge fund be provided with offering documents, it is good (and common industry practice) to do so. Most hedge funds provide written information to their investors in the form of a private offering memorandum. This document—referring to both the prospectus and subscription agreement-- goes by many names including: private placement memorandum, PPM, Offering Memorandum, OM or prospectus (PPM). Whatever it is called, the PPM is an extensive document individually created for each hedge fund. Do you need a set of offering documents for your hedge fund? For a reasonable fee, we will draft customized offering documents for all types of hedge funds. Contact Us for Assistance
Private Placement MemorandumIn 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 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. Although there are no specific disclosure requirements for offering documents, basic information about the hedge fund’s manager and the hedge fund itself typically, in fact is disclosed. The information provided is general in nature and it normally discusses in broad terms the hedge fund’s investment strategies and practices. For example, disclosures generally include the fact that the hedge fund’s manager may invest fund assets in illiquid, difficult to-value securities and that the hedge fund manager reserves the discretion to value such securities as it believes appropriate under the circumstances. Learn More About Hedge Fund Offering Documents
USA HEDGE FUND BENEFITSEven if you are based in another country, consider forming a U.S. hedge fund. 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 some hedge fund sponsors think about the purported negativity surrounding the United States, many more establish U.S. based hedge funds because of the minimal expenses associated with starting a U.S. hedge fund and the sheer convenience of having their U.S. based family members and/or other U.S. investors able to invest in the 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 U.S. regulation and low costs associated with forming a U.S. hedge fund.
MINIMAL INFRASTRUCTURE NEEDED To start a U.S. hedge fund, you generally need to form two business entities: the hedge fund and its investment manager. The hedge fund is typically set up as either a Delaware Limited Partnership (LP) or Limited Liability Company (LLC). For tax reasons, hedge fund sponsors based in New York or Texas may consider setting up three companies: the hedge fund, the investment manager and a management company. However, this is not required. The investment adviser can be set up as a LLC, or as some other type of business entity in your home state or country. We can form both entities for you quickly and for a low fee. Contact Us for Assistance Hedge fund sponsors based offshore can set up both a hedge fund and its management company in the United States.
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 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 U.S. 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 & virtual office service in Delaware.
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. Learn More About Delaware Companies 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 several 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. 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 & virtual office service in Delaware.
INCUBATOR HEDGE FUNDS If you delay drafting your hedge fund’s offering documents and are willing to defer collection of management and performance fees, you can operate an incubator hedge fund. In the United States, the incubator hedge fund is established with two companies—the hedge fund and its investment manager. In many other countries, a hedge fund incubator can be established with one company and the investment manager can be established at a later date. Until the time you have the offering documents ready for use with customers, you can deposit your own money as “seed capital,” and/or money from friends and family into the hedge fund and begin developing a track record. While you can accept money from friends and family you cannot charge them performance and management fees. One of the biggest advantages of the incubator hedge fund approach is that it allows you to start and fine-tune your investment strategy while generating a record of trading performance that can be used to transition to a full-fledged hedge fund when you are ready. The key difference between a full-fledged hedge fund and an incubator hedge fund is the ability to charge performance and management fees and the availability of offering documents. Learn More About Incubator Hedge Funds
CHARGING HEDGE FUND FEES In the United States, much is made about the terms “qualified client” and “accredited investor” for good reason. Learn More About Qualified Clients The reason is that for U.S. SEC-registered and in some states where investment adviser registration is required (i.e., California), the hedge fund performance fee can be charged only to qualified clients. The performance fee cannot be charged either to accredited or non accredited investors.
Hedge fund managers typically charge a management fee based on assets under management (AUM), and a performance fee (also called an incentive allocation, carried interest, performance share, etc.) based on the hedge fund's success. Management fees are, on average, considerably lower than the perceived industry standard of 2% and 20%. Many hedge fund managers lowered their fees in order to attract investors following recent market events. Some U.S. states regulate performance based fees. In some states, performance compensation can only be paid when the profits of the fund exceed a hurdle rate or on an annual basis. Be certain that your expectations about charging performance fees are correct. On the other hand, management fees can be charged to all investors. Learn More About Hedge Fund Performance and Management Fees Planning Tip: If the investors in your hedge fund are not qualified clients, avoid U.S. SEC registration or base the investment manager in a U.S. state or foreign country that does not require investment adviser registration.
ACCREDITED INVESTORS The SEC changes the definition of a qualified client and accredited investor. SEC rules permit certain private and limited offerings to be made without registration and without requiring specified disclosures, if sales are made only to "accredited investors." Generally, accredited investors include individuals with a minimum annual income or $1 million in net worth, excluding the value of the primary residence, and most entities and institutions with $5 million in assets. A non-accredited investor is simply one that does not meet the definition of an accredited investor. A U.S. hedge fund can accept up to 35 non-accredited investors. Learn More About Accredited Investors
SHOULD I AVOID NON-ACCREDITED INVESTORS? Not necessarily. However, if you allow non-accredited investors to invest in the fund, you need to have an initial financial statement prepared (read: audit). Make sure that your non-accredited investors have sufficient knowledge and experience in financial matters in order to evaluate the merits and risks of investing in your hedge fund. Learn More About Hedge Fund "Launch" Audits
HEDGE FUND BANKING & BROKERAGE SERVICES You cannot use your personal account as the hedge fund’s account. The hedge fund needs its own bank and brokerage account. The hedge fund does not need a prime broker or an introducing broker so you should consider using the broker with which you are already familiar and presumably have a good trading record. Nearly all small hedge funds start out with retail online brokers. Many hedge fund sponsors of offshore hedge funds want to use a U.S. broker. While it may take a while to open a U.S. brokerage account, the process can be speeded up considerably when offshore hedge fund has a bank account. In the United States, bank accounts can be opened over the Internet with minimal documentation and very modest initial deposits. In addition, operating costs—such as monthly bank maintenance fees - are relatively low in the United States when compared to most other countries. Banking in the United States presents a lesser burden to a hedge fund sponsor than banking in most other parts of the world. U.S. banks and brokers generally do not require a hedge fund’s investment manager to be licensed by a regulator in order to open accounts. For these reasons, the United States presents an extremely attractive option for sponsors of smaller hedge funds.
LEADING MEDIA CONTENT & ARTICLES ON HEDGE FUNDS & INTERNATIONAL TAX BY ATTORNEY HANNAH TERHUNE
Read articles on hedge funds and international tax planning by Hannah Terhune, a hedge fund and international tax attorney. Her articles are widely published on the Internet and recommended by TheStreet.com and other respected media. Contact Us for Articles & Reprint Rights
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HEDGE FUND ADMINISTRATION Unlike many other countries, there is no legal requirement in the United States to have a third party administrator. However, your investors and regulators see value in the appointment of a third-party administrator. A good administrator will provide detailed NAVs, performance records, brokerage statement reconciliation, and much more. Investors and regulators see value in the appointment of a third-party administrator and this because an independent person performs due diligence on new subscribers, calculates the share price and reports the same to investors. With this feature in place, the hedge fund manager is less able to overstate NAV, make false statements about performance or accept tainted subscription monies on behalf of the fund. Investors may feel a sense of comfort with the job of the administrator as a gatekeeper (i.e., controller of the hedge fund's cash movement), assuming, of course, that the administrator is asking the right questions on behalf of the fund. Learn More About Hedge Fund Administration and Costs
Use of Offshore Hedge Fund Manager to Avoid Home Country (or State) Hurdles A U.S. hedge fund’s investment manager can be set up in your home country, offshore, or in the United States. Unfortunately, many potential hedge fund managers live in countries where the capital formation, tax and regulatory hurdles to become a hedge fund manager are insurmountable. Many countries require a working background in finance, substantial education, and other credentials to be licensed as a hedge fund manager. Even if you have the necessary background and experience, you may not be able to obtain licensing in your home country simply because the regulators do not favor smaller one-man operations. If you are based in a country like that, consider setting yourself up an investment manager, either in the United States or elsewhere.
Set Up a U.S. Hedge Fund Manager In the United States, companies can be formed in minutes and a U.S. visit is not required. Learn More About U.S. Company Formations Note that you can use the hedge fund management company not only to serve as the fund’s investment manager, but also to operate a managed account business (i.e., unlike a hedge fund, managed account customer money is not pooled). When setting up a hedge fund manager outside of your home country (or state), arrange for a “virtual office” so that you have both a working and physical address outside your home country (or state). These arrangements allow you have to a hedge fund manager based in another part of the world with few, if any, regulatory barriers to hedge fund management. We offer company formation services in the United States. Contact Us for Assistance
Consider U.S. Investment Adviser Registration Many hedge fund sponsors based in other parts of the world choose to set up a U.S. investment manager to avoid home country licensing issues and to make the hedge fund more attractive to U.S. investors. Another reason for considering U.S. investment adviser registration is to satisfy a brokerage and/or bank’s requirement that a hedge fund’s manager be licensed somewhere before it is willing to supply bank and/or brokerages services to a new hedge fund. If your home country’s licensing requirements put investment manager registration out of reach, consider getting licensed in the United States. Fortunately, any foreign based investment manager is eligible to register with the U.S. Securities and Exchange Commission (SEC) without regard to the amount of assets under management. The SEC registration process is very simple and relatively streamlined. The SEC, it is a very light regulator of foreign-based hedge fund managers.
Use of Investment Adviser Sub-Contracts Many hedge fund sponsors opt to set up a hedge fund management company outside of their home country, whether for tax, commercial, or regulatory reasons. If you (as the hedge fund sponsor) set up the hedge fund management company outside of your home country, you should have a sub-agreement for "advisory" services between yourself and the offshore hedge fund management company. In the United States, an investment adviser is an investment manager. However, there is legal distinction between “investment manager” and “investment adviser” in most other countries. If you live in a country where a such a distinction exists, and if you set up the hedge fund's manager in such a country, you should position yourself through contracts as an investment adviser to the offshore investment manager. Such "advisory" services (i.e., an independent research analyst) is not a regulated business activity. To do this, you need an agreement between the offshore investment manager and a sub-agreement between the investment manager and the investment adviser.
The goal of the agreements is to allow you to offer research services to the offshore investment manager for a fee. When the investment advisory agreement is drafted properly and timely executed, you will be able to control the timing, tax character and amount of taxable income reportable in your home country. In addition, if the investment management agreement between the fund and the investment manager are drafted correctly and timely executed, further income deferral is possible. A hedge fund manager seeking to defer substantial amounts of management and performance fees should use third-party (i.e., “outside”) directors to ensure that the deferral mechanisms are respected for home country tax purposes.
Exemptions for U.S. Based Investment Mangers If you opt to set up a U.S. based investment manager, you may not be eligible for SEC registration. U.S. based investment advisers must register with the SEC or their “home” state. Any U.S. based investment adviser with less than $150 million assets under management must register with its “home” state--you are no longer allowed to SEC register. The good news is that most U.S. states have generous exemptions from registration as an investment manager. A hedge fund manager with less $150 million assets under management based in state that exempts it from state-level investment adviser registration, does not have to register at all with any regulatory authority; provided that the hedge fund does not trade spot forex, futures and or commodities. Learn More About NFA Registration As a result, a U.S. investment manager can be formed and ready for operation relatively soon after initiating the process.
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.
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)
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