From: Richard Kahn < To: Jeffrey Epstein <[email protected]> Subject: re: Tax Alert: Strategies to Address New York City's Unincorporated Business Tax Hedge Fund Audit Attack Date: Fri, 16 Dec 2011 13:58:04 +0000 Interesting article i thought you would like Richard Kahn HBRK Associates Inc. 301 East 66th Street, Suite 1OF New York, NY 10065 tel fax cell From: Sadis & Goldberg LLP Tax Group Reply-To: Date: Thu, 15 Dec 2011 10:13:39 -0500 (EST) To: Richard Kahn Subject: Tax Alert: Strategies to Address New York City's Unincorporated Business Tax Hedge Fund Audit Attack Sadis & Goldberg LLP Sadis Et Goldberg LLP Tax Alert Strategies to Address New York City's Unincorporated Business Tax Hedge Fund Audit Attack December 15, 2011 By Steven M. Etkind and Alex Gelinas Introduction: Certain management companies of hedge funds have recently been audited in connection with positions they took with regard to New York City Unincorporated Business Tax ("UBT"). The audits target the New York City tax benefits that principals of entities which serve as the general partner of hedge funds located in New York City have been able to derive in past years. Typical Management Company Structure: For many years, management companies of hedge funds have structured their businesses so that one legal entity (often referred to as the "Investment Manager") receives the management fees from a hedge fund and a second entity, often organized as an out-of-state EFTA00672561