• Money market fund reform becomes reality. What’s changing?

    On July 23, 2014 the US Securities and Exchange Commission (SEC) adopted a Final Rule that amends Rule 2a-7 of the Investment Company Act of 1940, which governs money market funds. These long anticipated amendments are designed to provide both structural and operational reform addressing an investor run on funds during a financial crisis, as was seen in 2008. The Final Rule becomes effective sixty days after publication in the Federal Register and provides for a two-year implementation period.
  • Deferred taxes on offshore fund incentive fees may not be dead after all

    In the recently published Revenue Ruling 2014-18, the Internal Revenue Service (IRS) concluded that certain nonqualified stock options (NSOs) or stock appreciation rights (SARs) would not be subject to the anti-deferral rules of Internal Revenue Code section 457A (section 457A). Generally, section 457A prohibits the deferral of income for service providers that perform services for nonqualified entities (i.e., foreign corporations based in offshore tax havens, entities substantially owned by tax-exempt organizations, or other tax-indifferent parties).