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.

The Securities and Commodities Safe Harbor

Funds that trade on the U.S. capital markets...

Stay ahead of the curve

In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.


  • Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
  • Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
  • Create custom alerts for specific article and case topics and so much more!

TRY LAW360 FREE FOR SEVEN DAYS

Hello! I'm Law360's automated support bot.

How can I help you today?

For example, you can type:
  • I forgot my password
  • I took a free trial but didn't get a verification email
  • How do I sign up for a newsletter?
Ask a question!