NYHFR Episode 15 – State Sourcing Income Rules & Considerations for Hedge Funds and Private Equity Funds

ByBritt Tunick

Gregory Kastner, a senior tax manager -financial services for Baker Tilly Virchow Krause, discusses some of the things that hedge funds and private equity funds should be aware of when it comes to state sourcing income rules. Among the specific things he touches on are:

  • Movement towards a single factor formula from the traditional three factors
  • Market based versus costs of performance sourcing regimes
  • “Look through” rules and uncertainties
  • Partnership level tax states
  • Possible income tax withholding requirements, statute of limitations issues and solutions such as composite returns