By Husayn Husayn Shihata, Abd Al-Sattar Abu Ghuddah
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Additional resources for A Guide to Accounting Zakah
S. partnership by a taxexempt institutional investor restricts on the investment strategy of the hedge fund or venture partnership by denying that the ability to borrow, issue debt, take on margin loans or any other form of collateralized loans, since such activity would trigger UBTI for these investors. S. S. investors. The objective is to block UBTI. S. investor are treated as dividends, which did not attract UBTI. S. hedge fund or venture fund. The offshore feeder fund itself would be subject to 30 percent withholding taxes on dividends, ordinary income, or income that is not deemed to be portfolio income.
Citizen without regard to country of residency. Many other developed countries, like Canada and the United Kingdom, have a tradition of exempting their nonresident citizens from tax on income earned outside the home country. S. persons outside the United States might be part of hidden and underhanded deals, not visible as taxable income in any taxing regime, and eminently suitable for concealment in secret Swiss bank accounts. S. S. businesses through outright fraudulent means, and who seek a vehicle not just for hiding these assets under the shroud of offshore banking secrecy but also to earn tax-free investment income from such assets.
5 million. S. securities brokerage firms offer excess-over-SIPC coverage from an independent insurance company, usually to the full extent of the assets. It is unclear whether investors paid attention to excess-over-SIPC coverage in a Madoff securities brokerage account, and Madoff probably did not buy such coverage. The subsequent Madoff litigation and SEC enforcement lacked the mention of claims upon an insurance underwriter for excess-over-SIPC coverage. Even if such an insurance policy existed, it may have had clear language clauses for denial of coverage in the event of fraud.
A Guide to Accounting Zakah by Husayn Husayn Shihata, Abd Al-Sattar Abu Ghuddah