The Internal Revenue Service (IRS) has published a practice unit on hedge fund basics (here).

Practice units are part of the knowledge material developed by the Large Business and International Division and serve both as job aids and training material on tax issues. They are not an official pronouncement of law, but in providing a general discussion, identify aspects of a structure or transaction which the IRS determines to be significant and set out an analysis of the tax position.

For further information, please contact Paul Hale or Enrique Clemente.