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Expert Analysis

Effectively Connected Income: A Close Look At The Rules

Law360, New York (September 11, 2015, 11:45 AM EDT) -- Short of a tornado or a cataclysmic earthquake obliterating midtown Manhattan or Greenwich, Connecticut, there is little that offshore fund managers fear more than the specter of their funds being treated as engaged in a United States trade or business. This fear is well-grounded; the incremental tax that results from this treatment may exceed 50 percent. This article outlines how a fund can remain "in bounds," without running afoul of the rules that can cause this expense. It ends with certain suggestions for structuring and best practices....

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