Jobs and Growth Tax Relief Reconciliation Act of 2003 Requires Planning for Rate Changes and New Dividend Rules PDF Download

Author: James N. Calvin
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ISBN:
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Languages : en
Pages : 0

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Book Description
The article reviews those aspects of the 2003 Tax Act of particular importance to investment managers and investment vehicles such as mutual funds and hedge funds. The spread between the highest tax rate on ordinary income and that on net capital gain that existed prior to the Act was approximately 18.6%. That spread has now been increased to 20%. Thus, the motivation to arbitrage the rate differences is only marginally increased by the Act. However, as in all things economic, action occurs at the margins, and the authors expect to see increased interest in holding capital assets for the long-term. With the reduction in the tax on net capital gains, U.S.-based managers of offshore hedge funds may want to reconsider the deferral of future fees through nonqualified deferred compensation arrangements. These fees are taxed as ordinary income, and generally at the highest individual tax rates when paid, and do carry substantial tax rate risk - that is, the risk that tax rates will be substantially higher than 35% when the fee is paid. Thus, these managers may want to consider the tax-efficiency of various fee arrangements. The authors also discuss qualifying dividend income, securities lending and short sales, the investment interest expense deduction, dividends on debt-financed stock, master-feeder structures, variable annuity accounts, and other topics relevant to the recent Act.