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Develop tax-efficient strategies for hedge funds and their investors and ensure compliance with applicable tax laws and regulations Review private placement memorandum (PPM/OM/LPA) with a particular focus on the tax section for compliance and tax minimization. Structure carried interest and performance fee arrangements to optimize tax efficiency for hedge fund managers Prepare Schedule K-1s and K-3s to provide comprehensive and accurate reporting to fund investors Preparation of partnership income tax returns for the fund, general partner and investment manager Conduct thorough analysis of investments to ensure compliance with regulations pertaining to wash sales, constructive sales, straddle, and mixed straddles

Thorough annual analysis of trader vs. investor funds to accurately determine the proper tax treatment of income and expenses Calculate unrelated business taxable income to ensure compliance with applicable tax laws and regulations for tax-exempt organizations Tax compliance of foreign investments such as PFICs, CFCs and foreign partnerships U.S. tax reporting and compliance for foreign investors including withholding pertaining to FDAP and ECI Preparate and file required state income tax withholding forms and reports, ensuring compliance with all applicable state laws and regulations Comply with Foreign Account Tax Compliance Act (FATCA), Common Reporting Standard (CRS) and Automatic Exchange of Information (AEOI) Respond to federal and state tax notices and provide assistance by working with the relevant tax authorities on behalf of our clients to resolve any issues in a timely and efficient manner

Analyze income for proper classification under IRC Sec. 475, Sec. 1256, Sec. 988

Conduct analysis for OID/market discount, swaps, and qualified dividends

Prepare partner tax allocations under IRC Sec. 704 (aggregate vs. layering)

In addition to our tax planning and compliance services listed above, our tax technology and automation solutions enable us to streamline tax compliance and reporting processes for our hedge fund clients. At Evolved, we are committed to delivering exceptional service and expert guidance to our clients, leveraging our expertise and technological resources to help them achieve their business goals while minimizing risk and enhancing tax efficiency. Our personalized approach ensures that each client receives the support they need to navigate the ever-evolving complex regulatory environment.


Matthew John McNally

Muhammad Junaid Senior Tax Manager D 46-539-2374 mjunaid@evolvedtax.com

Managing Partner

D 646-539-2371 mmcnally@evolvedtax.com

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