Wed, 12 July 2017
Taxation Section: Recent IRS Rulings Highlight Investor Control Issues for Fund of Funds Arrangements
From the June 2017 Taxing Times: The IRS has consistently spoken to the doctrine of investor control through private letter ruling requested by insurers and fund managers. And within the past decade, many of those requests, and the rulings issued in response, dealt with the concern that indirect investment in publicly-available funds could, depending on the structure employed, fall on the wrong side of the doctrine. Three recent private letter rulings, the subject of this article, represent a continuation of this trend. Written by John T. Adney and Bryan W. Keene. Read by Dan Theodore.