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Jeffrey Bowden

PFS
Tax Principal

A tax principal at Anchin and a member of the Firm’s Real Estate Industry Group and Financial Services Practice, Jeff has more than 20 years of experience developing and servicing complex partnership structures, corporations, high net worth individuals and family offices.

Jeffrey has experience servicing both owners of residential and commercial real estate. He advises in development, acquisitions and dispositions of real property, including 1031 exchanges, redemptions and other complex strategies in order to maximize tax efficiency.  Jeff has extensive knowledge in the taxation of partnerships, corporations and individuals.  He specializes in the tax implications of joint ventures, mergers, reorganizations and restructurings.  He analyzes potential transactions not only from a tax perspective but an overall business perspective in order to provide a more comprehensive picture on which clients can base their decisions.

Jeff’s Financial Services experience extends to servicing investment partnerships including private equity, fund of funds, distressed debt funds and real estate funds.  He frequently advises on structuring, limited partnership agreements, private placement memorandums and income tax planning for the fund and partners as well as the management companies.

Jeff is a frequent guest speaker and attendee at Financial Research Associates (FRA) events. He is also an active member of the Real Estate Board of New York, CPE for CPAs and the Wall Street Tax Association.

  • Tax Planning and Compliance
  • Financial Services
  • Real Estate

News

  • Tax Court Refuses to Follow Rev. Rul. 91-32 in Grecian Magnesite Mining DecisionAugust 23, 2017

    In a recent decision, the U.S. Tax Court refused to accord deference to an Internal Revenue Service (IRS) administrative ruling treating the sale of partnership interests as a sale of assets the partnership uses in a U.S. trade or business, thereby subjecting the resulting gain to taxation as income effectively connected to a U.S. trade or business.

  • Proposed Carried Interest Bills Still AliveJuly 10, 2017

    Earlier this year, we shared information with you about several proposed bills that would increase taxes due on investment performance allocations, commonly known as carried interest. Carried interest is the share of profits that fund managers receive in exchange for managing investments. The controversy over carried interest arises because the current tax rules allow managers to pay taxes on portions of the carried interest allocation at the (long term) capital gains rate rather than the higher tax rate that normally applies to ordinary income.

  • SEC Clarifies Three Confusing Situations For The Custody RuleMay 25, 2017

    The SEC’s Custody Rule continues to be a headache for registered investment advisers. The conditions are so unclear, it’s easy to inadvertently trigger custody rule violations. To help advisers adjust, the SEC recently issued clarification for three confusing situations under the rule.

  • SEC Identifies Top 5 Compliance Issues Found in OCIE ExaminationsApril 6, 2017

    Call it a wake-up call for registered investment advisers—the Securities and Exchange Commission (SEC) issued a Risk Alert, highlighting the top five compliance issues found in deficiency letters sent to SEC-registered investment advisers.

  • 2016 Real Estate Year-End Tax Planning UpdateDecember 21, 2016

    Along with the results of the 2016 presidential election comes a dramatic shift in the political priorities of those in power and a strong likelihood that drastic tax reform lies ahead in 2017. While many of the details are still unknown and may not be fully actualized and actionable until well into the next year, getting a head start on planning and understanding the impact of various potential scenarios as early as possible is essential.

  • Net Worth Threshold for “Qualified Clients” Increased by SECJuly 28, 2016

    The U.S. Securities and Exchange Commission (“SEC”) has decided to increase the net worth test threshold for “qualified clients” effective August 15, 2016.

  • New Tax Audit Rules Constitute a Radical Change for PartnershipsJanuary 27, 2016

    Late in 2015, Congress passed the Bipartisan Budget Act of 2015 (the Act), which includes a complete overhaul of the procedures that apply to Internal Revenue Service (IRS) audits of partnerships and limited liability companies (LLCs) taxed as partnerships and their partners.

  • 2016 SEC & FINRA Exam PrioritiesJanuary 25, 2016

    The Office of Compliance Inspections and Examinations (“OCIE”) of the Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”) have released their Exam Priorities for 2016. Each of the regulators have organized their focus around a number of key issues.

  • 2015 SEC Examination Priorities AnnouncedJanuary 20, 2015

    Last week, the SEC announced its examination priorities for 2015. Three themes highlighted the areas of focus for the SEC’s Office of Compliance Inspections and Examinations ("OCIE"): Protection of retail investors and investors saving for retirement, assessing market-wide risk and using enhanced data analysis to identify those engaged in potential illegal activity.

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