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Carried Interest
Carried interest, or carry, in finance, is a share of the profits of an investment paid to the investment manager specifically in alternative investments (private equity and hedge funds). It is a performance fee, rewarding the manager for enhancing performance.Lemke, Lins, Hoenig and Rube, ''Hedge Funds and Other Private Funds: Regulation and Compliance'', §13:20 (Thomson West, 2013–2014 ed.). Since these fees are generally not taxed as normal income, some believe that the structure unfairly takes advantage of favorable tax treatment, e.g. in the United States. In this regard, it is often referred to as the carried interest loophole. '' The Hill'' referred to it as "Wall Street's favorite tax break." History The origin of carried interest can be traced to the 16th century when European ships were crossing to Asia and the Americas. The captain of the ship would take a 20% share of the profit from the carried goods to pay for the transport and the risk of sailing over oceans. T ...
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Fund Structure
Fund may refer to: * Funding is the act of providing resources, usually in form of money, or other values such as effort or time, for a project, a person, a business, or any other private or public institution ** The process of soliciting and gathering funds is known as fundraising * An investment fund, often referred to as a fund ** Hedge fund, an investment vehicle open only to investors who are qualified in some way ** Mutual fund, a specific type of investment fund which pools money from many investors to purchase securities ** Sovereign wealth fund, a state-owned investment fund * Fund accounting, an accounting system used for recording resource use under limitations imposed by a donor or regulator *Meir Fund Meir Fund is an American Orthodox rabbi, Kabbalist, and spiritual leader of Congregation ''Sheves Achim, 1517 Avenue H,'' in Brooklyn, New York Brooklyn is a Boroughs of New York City, borough of New York City located at the westernmost en ..., American rabbi *FUN ...
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Distribution Waterfall
In private equity investing, distribution waterfall is a method by which the capital gained by the fund is allocated between the limited partners (LPs) and the general partner (GP). Overview In a private equity fund, the general partner manages the committed capital of the limited partners. The GP usually commits some amount to the fund (the "GP co-investment"), usually 1 to 2% of the commitment. When distributing the capital back to the investor, hopefully with an added value, the general partner will allocate this amount based on a waterfall structure previously agreed in the Limited Partnership Agreement. A waterfall structure can be pictured as a set of buckets or phases. Each bucket contains its own allocation method. When the bucket is full, the capital flows into the next bucket. The first buckets are usually entirely allocated to the LPs, while buckets further away from the source are more advantageous to the GP. This structure is designed to encourage the general partner ...
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Internal Revenue Service
The Internal Revenue Service (IRS) is the revenue service for the Federal government of the United States, United States federal government, which is responsible for collecting Taxation in the United States, U.S. federal taxes and administering the Internal Revenue Code, the main body of the federal statutory tax law. It is an agency of the United States Department of the Treasury, Department of the Treasury and led by the Commissioner of Internal Revenue, who is appointed to a five-year term by the President of the United States. The duties of the IRS include providing tax assistance to taxpayers; pursuing and resolving instances of erroneous or fraudulent tax filings; and overseeing various benefits programs, including the Affordable Care Act. The IRS originates from the Commissioner of Internal Revenue, a federal office created in 1862 to assess the nation's first income tax to fund the American Civil War. The temporary measure funded over a fifth of the Union's war expens ...
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United States Court Of Appeals For The Eighth Circuit
The United States Court of Appeals for the Eighth Circuit (in case citations, 8th Cir.) is a United States federal court with appellate jurisdiction over the following United States district courts: * Eastern District of Arkansas * Western District of Arkansas * Northern District of Iowa * Southern District of Iowa * District of Minnesota * Eastern District of Missouri * Western District of Missouri * District of Nebraska * District of North Dakota * District of South Dakota The court is composed of 11 active judges and is based primarily at the Thomas F. Eagleton United States Courthouse in St. Louis, Missouri, and secondarily at the Warren E. Burger United States Courthouse in St. Paul, Minnesota. It is one of 13 United States courts of appeals. In 1929, Congress passed a statute dividing the Eighth Circuit that placed Minnesota, Iowa, North Dakota, South Dakota, Nebraska, Missouri, and Arkansas in the Eighth Circuit and created a Tenth Circuit that included ...
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Present Value
In economics and finance, present value (PV), also known as present discounted value (PDV), is the value of an expected income stream determined as of the date of valuation. The present value is usually less than the future value because money has interest-earning potential, a characteristic referred to as the time value of money, except during times of negative interest rates, when the present value will be equal or more than the future value. Time value can be described with the simplified phrase, "A dollar today is worth more than a dollar tomorrow". Here, 'worth more' means that its value is greater than tomorrow. A dollar today is worth more than a dollar tomorrow because the dollar can be invested and earn a day's worth of interest, making the total accumulate to a value more than a dollar by tomorrow. Interest can be compared to Renting, rent. Just as rent is paid to a landlord by a tenant without the ownership of the asset being transferred, interest is paid to a lender by ...
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Amount Realized
Amount realized, in US federal income tax law, is defined by section 1001(b) of Internal Revenue Code. It is one of two variables in the formula used to compute gains and losses to determine gross income for income tax purposes. The excess of the amount realized over the adjusted basis is the amount of realized gain (if positive) or realized loss (if negative). Computation of gain and loss is governed by section 1001(a) of the Code. Statutory definition Section 1001(b) defines the amount realized as "the sum of any money received plus the fair market value of the property (other than money) received." Generally, it is the value of what the taxpayer receives in the exchange. Calculating amount realized To have an "amount realized" there must be a kind of exchange, known as a "realization event." The first step in calculating the amount realized is determining when an exchange that qualifies as a "realization event" has occurred. Section 1001 requires that it be an exchange through ...
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Sweat Equity
Sweat equity refers to work one does to build up value without a salary. This ownership interest, or increase in value, is created as a direct result of hard work by the owner. For example, homeowners who renovate or repair their house themselves are investing in sweat equity that increases the value of their home. Or it could be a non-monetary benefit that a company's stakeholders give in labour and time, rather than a monetary contribution, that benefit the company. In some cases, sweat equity may be rewarded in the form of sweat equity shares. These are shares given out by a company in exchange for labour and time rather than a monetary amount."Sweat Equity Shares." Court Uncourt, vol. 7, no. 6, 2020, p. 21-22. HeinOnline, https://heinonline.org/HOL/P?h=hein.journals/counco7&i=264 Sweat equity in real estate Sweat equity has an application in business real estate, for example, where the owners put in effort and toil to build the business, in real estate where owners can perf ...
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Amount Realized
Amount realized, in US federal income tax law, is defined by section 1001(b) of Internal Revenue Code. It is one of two variables in the formula used to compute gains and losses to determine gross income for income tax purposes. The excess of the amount realized over the adjusted basis is the amount of realized gain (if positive) or realized loss (if negative). Computation of gain and loss is governed by section 1001(a) of the Code. Statutory definition Section 1001(b) defines the amount realized as "the sum of any money received plus the fair market value of the property (other than money) received." Generally, it is the value of what the taxpayer receives in the exchange. Calculating amount realized To have an "amount realized" there must be a kind of exchange, known as a "realization event." The first step in calculating the amount realized is determining when an exchange that qualifies as a "realization event" has occurred. Section 1001 requires that it be an exchange through ...
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Capital Gain
Capital gain is an economic concept defined as the profit earned on the sale of an asset which has increased in value over the holding period. An asset may include tangible property, a car, a business, or intangible property such as shares. A capital gain is only possible when the selling price of the asset is greater than the original purchase price. In the event that the purchase price exceeds the sale price, a capital loss occurs. Capital gains are often subject to taxation, of which rates and exemptions may differ between countries. The history of capital gain originates at the birth of the modern economic system and its evolution has been described as complex and multidimensional by a variety of economic thinkers. The concept of capital gain may be considered comparable with other key economic concepts such as profit and rate of return; however, its distinguishing feature is that individuals, not just businesses, can accrue capital gains through everyday acquisition a ...
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Congressional Research Service
The Congressional Research Service (CRS) is a public policy research institute of the United States Congress. Operating within the Library of Congress, it works primarily and directly for members of Congress and their committees and staff on a confidential, nonpartisan basis. CRS is sometimes known as Congress' think tank due to its broad mandate of providing research and analysis on all matters relevant to national policymaking. CRS has roughly 600 employees, who have a wide variety of expertise and disciplines, including lawyers, economists, historians, political scientists, reference librarians, and scientists. In the 2023 fiscal year, it was appropriated a budget of roughly $133.6 million by Congress. Modeled after the Wisconsin Legislative Reference Bureau, CRS was founded during the height of the Progressive Era as part of a broader effort to professionalize the government by providing independent research and information to public officials. Its work was initially ma ...
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Blackstone Group
Blackstone Inc. is an American alternative investment management company based in New York City. It was founded in 1985 as a mergers and acquisitions firm by Peter Peterson and Stephen Schwarzman, who had previously worked together at Lehman Brothers. Blackstone's private equity business has been one of the largest investors in leveraged buyouts in the last three decades, while its real estate business has actively acquired commercial real estate across the globe. Blackstone is also active in credit, infrastructure, hedge funds, secondaries, growth equity, and insurance solutions. As of May 2024, Blackstone has more than $1 trillion in total assets under management, making it the world's largest alternative investment firm. History Founding and early history Blackstone was founded in 1985 by Peter G. Peterson and Stephen A. Schwarzman with (equivalent to $million in ) in seed capital. The founders derived their firm's name from their names: "Schwarz" is German for ...
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Initial Public Offering
An initial public offering (IPO) or stock launch is a public offering in which shares of a company are sold to institutional investors and usually also to retail (individual) investors. An IPO is typically underwritten by one or more investment banks, who also arrange for the shares to be listed on one or more stock exchanges. Through this process, colloquially known as ''floating'', or ''going public'', a privately held company is transformed into a public company. Initial public offerings can be used to raise new equity capital for companies, to monetize the investments of private shareholders such as company founders or private equity investors, and to enable easy trading of existing holdings or future capital raising by becoming publicly traded. After the IPO, shares are traded freely in the open market at what is known as the free float. Stock exchanges stipulate a minimum free float both in absolute terms (the total value as determined by the share price multiplied ...
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