This is Module 15 of the Henley Executive Hedge Fund Program (HEHFP), which discusses the crucial issue of tax planning in structuring funds and management companies, including such factors as transfer pricing and economic substance laws. It also addresses the particular issues introduced by US investors. This module also covers the role of the Auditor, and what a fund can expect to encounter in the audit process. The issues related to accounting practices, such as fair value accounting, allocation of incentive fees, side pockets, and differences between GAAP and IFRS methodologies were introduced. Finally, the operational/accounting controls, and fraud were discussed.

This module is a 3.5-hour (approx. study time) course and is eligible for 2 SFC CPT/PWMA OPT hours.

Check out the other modules in the Program:

• Module 1: Overview of the Hedge Funds Industry
• Module 2: Structuring & Setup
• Module 3: Capital Raising & Investor Relations
• Module 4: Portfolio Management
• Module 5: Portfolio Risk Management
• Module 6: Markets and Trading
• Module 7: Prime Brokerage Services
• Module 8: Business Management & Fund Administration
• Module 9: Operations and Technology
• Module 10: Operational Risk Management & Operational Due Diligence
• Module 11: Legal
• Module 12: Ethics (2023)
• Module 13: Compliance
• Module 14: Fund Governance
• Module 16: Human Resources
• Module 17: Pitchbook Formation

By the end of this module, you will be able to:
- Tell the key fund structuring considerations
- State the key tax issues relevant to the fund sector
- Describe the key tax issues for US investors
- Recognise the audit requirements for hedge funds
- List the key accounting issues relevant to the funds

Part 1 - Pre-reading materials
(i) OECD Transfer Pricing Guidelines 2017
(ii) Economic Substance Laws
(iii) Definition of UBTI
(iv) Difference between IFRS and US GAAP
(v) US Tax Reform Hedge Fund
(vi) KPMG’s Illustrative Financial Statements Hedge Funds 2020
(vii) Schedule K-1
(viii) Form 8621
(ix) US IRS's tax symbology

Part 2 - Presentation Slides of the eCourse

Part 3 - Tax, Audit & Accounting eCourse*
(i) Introduction
(ii) Section 1 - Tax: Fund Structuring Considerations
(iii) Section 2 - Tax: Manager Structuring Considerations
(iv) Section 3 - Tax Implications of US Investors
(v) Section 4 - Audit
(vi) Section 5 - Accounting for Investment Companies
(vii) Section 6 - Operational Controls and Accounting
(viii) Conclusion

Part 4 - Quiz*
The quiz consists of 15 questions where learners have 3 attempts to achieve at least 80% with correct answers as a pass.

Part 5 - Post-reading materials
(i) How Transparency is Transforming Tax in a Digital Era?
(ii) Overview of the differences between IFRS and US GAAP
(iii) Treasure Islands: Tax havens and the Men who Stole the World by Nicholas Shaxton

* mandatory parts to complete

(1) Hedge Fund professionals seeking to enhance their knowledge
(2) Individuals looking to start a Hedge Fund
(3) Service providers e.g., Banking, Risk, Compliance and IT professionals, Lawyers, Fund Administrators