For fund managers operating under Model 2 IGAs, U.S. FATCA compliance requires direct engagement with the IRS, precise reporting, and ongoing oversight. Clear processes and reliable support can make the difference between routine compliance and unnecessary risk. […]
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Understanding ROI gives business leaders a clear view of which initiatives are creating value and which need reevaluation. With the right metrics, companies can make sharper, more confident decisions that accelerate growth and profitability. […]
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Financial forecasting plays a critical role in helping businesses anticipate cash flow, assess risks, and plan strategically. By using pro forma statements and accurate projections, companies can make informed financial decisions that support stability and long-term growth. […]
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In structuring a private equity fund or other tiered partnership arrangement, care must be taken to ensure the safe harbor for profits interest received for services is preserved. It is important in the issuance of profits interest to carefully document and substantiate capital account book-ups to protect against IRS contest that the interest is a capital interest. […]
This case highlights the need for C corporations to have a dividend policy and history. It also highlights the need to carefully consider the compensation paid each year to the shareholder-employee of a closely held corporation to have better support of reasonable compensation in order to avoid the recharacterization of deductible compensation to nondeductible dividend distributions. It would likely have been tax advantageous for the Taxpayer to be an S corporation. […]
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