Because of the confusion resulting from this informal expansion of what constitutes a foreign financial account, as well as compliance burdens in compiling the information needed to complete the FBAR, the IRS has extended for some FBAR filers the June 30, 2009 due date to September 23, 2009 (the "safe harbor"). The IRS describes the safe harbor as covering: "Taxpayers who reported and paid tax on all of their 2008 taxable income but only recently learned of their FBAR filing obligation" and do not have enough time to file by June 30, 2009, have until September 23, 2009 to file. The "only recently learned of their FBAR filing obligation" appears to be an oblique reference to the informal IRS guidance earlier this month. FBAR filings that are eligible to use this safe harbor are instructed to send their "delinquent" FBAR and their 2008

Every U.S. taxpayer that owned a foreign financial account or had signature authority over a foreign bank account or financial account in 2008 must file a Treasury Form TD F 90-22.1 by June 30, 2009. The form, which was extensively revised and greatly lengthened in October 2008, is filed separately with the Treasury Department, provided that the aggregate value of the accounts exceeded $10,000. Failure to file is punishable by up to a $10,000 fine and, in egregious cases criminal punishment.

The Treasury Department has released its lengthy explanation of the President's wide-ranging tax proposals. The President aims to deliver on both tax "fairness," especially the ending of perceived tax abuses and "loopholes," and increasing federal tax revenues. Particularly hard hit would be U.S. businesses with operations outside the U.S. and the financial services sector.

The Internal Revenue Service (the "IRS") has issued two rulings on participants in the life settlements industry. This ever-expanding investment strategy entails the sale of life insurance policies to third party investors, who may themselves re-sell the policies or hold them to maturity (the death of the insured). The life settlements industry has grown from a small "niche" market to a major international market where billions of dollars of capital are invested. Both rulings are "revenue rulings," which are rulings of general applicability and a high level of authority, albeit not as authoritative as regulations.

It is with great sadness that we announce that Dennis Hirsch passed away Sunday, March 29. Dennis, Partner and founder of the Firm's San Francisco office, will be sadly missed by his colleagues, clients, family and friends. He was 37.

In this alert, we update you about the Service's Revenue Ruling 2009-9 and Revenue Procedure 2009-20, both issued March 17, 2009. The Ruling provides the IRS's view of the legal rules and the Procedure provides a "Safe Harbor" that should be approached with caution.

Senator Baucus, Democrat of Montana and chair of the Finance Committee, announced that he is introducing a bill in response to Senator Levin's bill. The draft Baucus bill is all about the process - more information reporting burdens and increased penalties for noncompliance.

The Banks Committee of the Connecticut General Assembly voted to pass a bill that will raise the minimum financial qualifications for investors in Connecticut based hedge funds.

Senator Carl Levin, Democrat of Michigan, has "declared war" on offshore funds managed by U.S. inves

This bill would collect a 0.25% (one-quarter of one percent) excise tax ("stamp tax") on the gross proceeds of all securities and commodities transactions on U.S. markets.

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On February 17th, the SEC charged Robert Allan Stanford and three of his companies for orchestrating

The economic stimulus bill (the "American Recovery and Reinvestment Act of 2009," the "Bill") passed by the House and under consideration by the Senate will be a hugely expensive undertaking if enacted. Because of the Bill's massiveness, the Bill's important tax proposals have largely gone unnoticed. We discuss here the tax changes that are important to participants in the financial markets.

This Tax Alert covers IRS Notice 2009-8, "Interim Guidance Under Section 457A" (the "IRS Notice"), emphasizing exceptions to the 2008 no-fee deferral rule that are of interest to financial services companies.

The order has been signed by the Court approving the forms to make SIPC claims regarding Madoff. The liquidator will mail you the forms by January 9th. You have 60 days from the date that Notice is published in the Wall Street Journal, to put forth your claims. As the sixty days does not run from when you receive the form, please assume that the clock is running from today, just to be safe. Generally speaking, you are entitled to receive your "net equity", which is the liquidation value of the account on the date of filing minus indebtedness to the debtor, such as margin. The order also lays out the procedure for challenging the liquidator should your claim be denied or disallowed in part. Please contact Douglas Hirsch at 212-573-6670 or email dhirsch@sglawyers.com

This tax alert summaries relief that may be available: (1) filing a 2008 tax return claiming an ordi

On December 11th, the SEC charged Mr. Madoff in a $50 billion dollar Ponzi scheme.

We analyze classic cost effective tax strategies for hedge fund managers of U.S. funds.

The 2008 Institutional Investor Alpha Awards ranks Sadis & Goldberg number 5 for onshore law firms.

Tax Alert: The President signed the "financial bailout" and tax relief bill.

Ron Geffner outlines the tools that a hedge fund manager needs to deal with the liquidity crises...

The first Form SH filing must be filed electronically with the SEC on Monday, September 29, 2008....

On September 19, 2008, the SEC issued several orders addressing short selling ...

Tax Alert: Baucus/Grassley I - Senate Bipartisan Threat to Fee Deferrals for Offshore Manage

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SEC states that Rule 206(4)-3 does not apply to cash payments by a registered investment adviser....

Two recent IRS rulings consider the treatment of investors' deductions of two types of hedge funds.

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Tax Alert

Alert announcing that the California Department of Corporations will not proceed with Proposal 41/06

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Article written by Ron Geffner in Complinet Inc. Magazine.

Article written by Ron Geffner in HFMWeek's US East Coast 2008 Report.

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Article written by Steven Etkind from Private Investor Forum

The House Ways & Means Committee passed the "Temporary Tax Relief Act of 2007," proposing two major

The IRS announced on November 1, 2007 that it opened an inquiry into "suspected tax abuses"

Section 409A of the tax law provides requirements for deferred compensation plans to avoid taxation

Article written by Steven Etkind and Roger Lorence from the Derivatives Report.

These proposed rule changes are an overhaul of the regulatory framework that governs California

The California Department of Corporations has proposed changes in its regulations for advisers.

Section 1256(g)(2) of the Internal Revenue Code treats foreign currency contracts as ...

On February 3, 2006, New York Governor George Pataki signed into law Senate Bill No. 85-A