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Taxation of private equity and hedge funds : ウィキペディア英語版 | Taxation of private equity and hedge funds
Private equity funds and hedge funds are private investment vehicles used to pool investment capital, usually for a small group of large institutional or wealthy individual investors. They are subject to favorable regulatory treatment in most jurisdictions from which they are managed, which allows them to engage in financial activities that are off-limits for more regulated companies. Both types of fund also take advantage of generally applicable rules in their jurisdictions to minimize the tax burden on their investors, as well as on the fund managers. As media coverage increases regarding the growing influence of hedge funds and private equity, these tax rules are increasingly under scrutiny by legislative bodies. 〔Michael S. Knoll, ''Article: The Taxation of Private Equity Carried Interests: Estimating the Revenue Effects of taxing Profit Interests as Ordinary Income'', 50 WM. & MARY L. REV. 115, 117 (2008).〕 Private equity and hedge funds choose their structure depending on the individual circumstances of the investors the fund is designed to attract, as discussed below. ==Basic structure: U.S. domestic fund== A private equity or hedge fund located in the United States will typically be structured as a limited partnership, due to the lack of an entity-level tax on partnerships and other flow-through entities under the U.S. tax system.〔See generally, subchapter K of chapter 1 of the Internal Revenue Code, Title 26 of the U.S. Code.〕 The limited partners will be the institutional and individual investors. The general partner will be an affiliate of the manager of the fund. Typically, the manager of the hedge fund is compensated with a fee based on 2% of the gross assets of the fund, and a profits interest entitling the manager (or, more typically, its affiliated general partner) to 20% of the fund's return (subject, in many cases, to minimum guaranteed returns for the limited partners).
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