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Hedge Fund Tax Rate
Posted on 4/27/12 at 3:25 pm
Posted on 4/27/12 at 3:25 pm
How do hedge fund managers get away with a 15% tax rate? I know its a loop hole that has to do with income being counted as long term capital gains but I am not sure exactly how all that works. Can anyone shed some light on the subject?
Posted on 4/27/12 at 3:37 pm to TheDirty1
You're thinking of private equity and carried interest, not hedge funds.
Posted on 4/27/12 at 3:42 pm to kfizzle85
Hedge Funds too. They can fall under that same loophole umbrella that PE principals use (whereas components of their compensation are treated as capital gains and not ordinary income). In some situations the compensation is considered carried interest in the same manner that it more formally is with PE/VC firms.
Closing them wouldn't result in substantial deficit reduction or anything, but it is a joke.
It's also a nice thing for populists to poke at. We'll undoubtedly hear about it non-stop this fall.
Closing them wouldn't result in substantial deficit reduction or anything, but it is a joke.
It's also a nice thing for populists to poke at. We'll undoubtedly hear about it non-stop this fall.
This post was edited on 4/27/12 at 3:57 pm
Posted on 4/27/12 at 3:45 pm to RemouladeSawce
quote:
Hedge Funds too. They are under the same loophole umbrella that PE principals use as well whereas large amounts of their compensation are treated as capital gains and not ordinary income. It's a joke.
I agree that the principle itself is "unfair". But they'd be idiots not to take advantage of the opportunity. PE firms especially have the excuse because what they're doing has around 5 year time horizon anyway and should be considered LT capital gains. I didn't realize that this was the case for hedge funds though
Posted on 4/27/12 at 3:50 pm to GregYoureMyBoyBlue
quote:I don't blame them at all. I would do the same if I were a GP. There is also validity with the capital gains argument due to the LT time horizon required of certain PE firms before exit and HFs with strategies that are LT-oriented.
I agree that the principle itself is "unfair". But they'd be idiots not to take advantage of the opportunity.
CPAs who work with these vehicles please chime in.
This post was edited on 4/27/12 at 3:58 pm
Posted on 4/27/12 at 4:05 pm to RemouladeSawce
I guess its possible with hedge funds that have long time horizons, but would you not agree that it is significantly more prevalent in private equity than it is in hedge funds? eta: I appreciate you pointing it out, I guess I forgot there's such thing as hedge funds that actually hold long positions in anything. We do carried interest valuations for private equity all the time, have never done one for a hedge fund though (although we do other valuation work for them all the time).
This post was edited on 4/27/12 at 4:16 pm
Posted on 4/27/12 at 7:46 pm to kfizzle85
You have to remember these entites are taxed as partnerships. So they can allocate income and losses in very creative ways as long as the allocations have substantial economic effect. It's possible to allocate short-term captial gains to the investors first and the long-term cpital gains to the fund manager first for example.
Many years ago, before dsitributions in kind of shares of stock were treated as distributions of cash, I performed many complex calculations pertaining to disproportionate distributions of shares of stock in specific companies to specific investors in venture capital funds. Those distributions were allowed if at the end of the day the total distributions to all partners were made in accordance with the terms of the partnership agreement, and they had substantial economic effect.
Many years ago, before dsitributions in kind of shares of stock were treated as distributions of cash, I performed many complex calculations pertaining to disproportionate distributions of shares of stock in specific companies to specific investors in venture capital funds. Those distributions were allowed if at the end of the day the total distributions to all partners were made in accordance with the terms of the partnership agreement, and they had substantial economic effect.
Posted on 4/27/12 at 10:26 pm to Poodlebrain
Most of what we do is valuation related (endgame is tax most of the time), so our purpose is mainly to come up with a "fair value." I typically read through the partnership agreements, determine how long it would take an LP (bossman does the MPs) to fully exit the investment, and use an option model to discount the indicated value. From there we do some more financial hocus pocus, but that's the gist of my private equity/hedge fund experience. Its kind of cool in the sense that they let me talk to a lot of the funds since I'm not a complete assclown, and I also get to see their statements, but the carried interest valuation the bossman does with monte carlos etc is so above and beyond me it really makes me feel incredibly dumb.
Posted on 4/28/12 at 7:20 am to RemouladeSawce
Just to clarify, typically the allocation to a manager (i.e., GP in an lp) of a hedge is also characterized as carried interest, just like in a PE fund. The structures are the same, so the allocation mechanisms are the same (although timing of the allocations differs). It's just that hedge funds usually do not have long term investments, so the carried interest does not get ltcg treatment.
I think the confusion comes from the all knowing media, which can't be bothered with specifics. It's easier to just say hedge funds. Oh, and those private jets, don't forget about those private jets.
I think the confusion comes from the all knowing media, which can't be bothered with specifics. It's easier to just say hedge funds. Oh, and those private jets, don't forget about those private jets.
Posted on 4/28/12 at 7:23 am to Poodlebrain
quote:
It's possible to allocate short-term captial gains to the investors first and the long-term cpital gains to the fund manager first for example.
I'd be interested in hearing how this would be done in a typical hedge fund. I could see in a jv type arrangement or in a vc model, but in my experience, most hedge funds just have typical pro rata allocations of net gains and losses.
Posted on 4/29/12 at 2:30 pm to Mo Jeaux
So if the hedge fund doesn't only have long term gains the "carried interest" or compensation to the hedge fund manager is still taxed at a short term gain rates? Am I reading that right? Thanks for all the help.
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