The greatly increased activities of offshore hedge funds in the U.S. debt markets and the increased propensity of hedge funds to make loans have dramatically elevated the visibility of the “trade or business” status issue.
Listen to this short podcast with Len Schneidman, of counsel with Pepper Hamilton’s Tax Practice Group and resident of our Boston office, as he discusses this issue which has drawn the attention of the IRS and the popular press.
Len’s recently published book, U.S Taxation of Foreign Portfolio Investors, is the only professional book dedicated to the complex analysis of the critical U.S. and cross-border rules and regulations needed by foreign portfolio investors to minimize U.S. taxes on dividends, interest and trading gains. Please email podcasts@pepperlaw.com if you are interested in receiving a complimentary copy of the first chapter of his book.
(Running Time: 7:53)
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