Tax Counsel to Private Client Regarding Trust, Trading Losses

Private Client

Advised wealthy private client, a U.S. citizen, on the viability of treating a trust as a business trust, and on the most tax efficient approach to offset $1 million in losses incurred through day trading from within the trust.

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Advised $5 billion hedge fund on synthetic investment, through total return swap, in publicly-traded REIT to avoid withholding tax on distributions to fund’s foreign feeder.
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