Chief Counsel Advisory 201501013 Warns Foreign Fund Manager Activity In The U.S. May Constitute Trading In Stock And Securities For The Fund And Its Foreign Investors
In CCA 201501013 (1/2/2015) the Office of Chief Counsel of the IRS ruled that the lending and underwriting (stock distribution) activities of a foreign partnership (Fund) were considerable, continuous and regularly carried on, and therefore that such activities, conducted on its behalf through its U.S. agent (Fund Manager) under the particular facts before it, constituted the carrying on of a U.S. trade or business and the activities. The Fund did not, in its view, […]