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Making sense of hedge fund tax allocations

May 20, 2020

Hedge fund managers are required to prepare and distribute Schedule K-1s to their investors. K-1s show an investor’s share of a fund’s income, gains, losses, credits and other tax items, which individual investors report to the IRS on their income tax returns.

This process causes confusion every year.

Many hedge fund investors open their K-1s and see allocation figures that don’t match their year-end account statements.

Why don’t hedge fund statements agree?

Several aspects of hedge funds can cause this confusion, but two factors stand out:

  1. Hedge funds can have investments in numerous marketable securities.
  2. Hedge funds are open-ended. Partners can invest and redeem capital periodically throughout the year.

How marketable securities affect hedge fund statements

In marketable securities, gains and losses are reported differently. Gains and losses due to changes in security values are required to be recorded by GAAP, but there is no taxable event until the securities are sold or liquidated. Essentially, unrealized gains and losses are not recognized for tax purposes.

There are many moving parts associated with hedge funds, too. Funds may buy and sell securities throughout the year, and investors can put money into the fund and redeem it throughout the year. This constant activity can result in tax allocations that vary significantly from an investor’s expectations.

Standards for consistent hedge fund allocation   

Over the years, an industry standard evolved to help ensure that allocations are consistent with governing tax laws. One critical component of the law states that allocations must be consistent with the economic arrangement.

For instance, if a partner is allocated the gain or loss for book purposes, that same partner should be allocated the gain or loss for tax purposes as well. It’s easy to understand why the IRS would not accept a tax gain that is distributed among all the fund partners for book purposes but then collectively allocated to only one tax-exempt partner on the partnership’s return.

How to minimize disparity in hedge fund allocation   

Another IRS mandate minimizes disparity during partnership allocations. Disparity refers to the difference between the gains and losses that a partner has recognized for book purposes and the gains and losses that same partner is taxed on.

For investment partnerships, these differences are mainly caused by unrealized gains. They can also result from any other temporary M-1 or book/tax difference.

Logically, reducing disparity makes sense. For example, a partner that participated in a fund when unrealized gains increased their account value should recognize more taxable gains than an investor that did not enjoy a similar increase in their book account value. However, with the complexities of a hedge fund’s moving parts, equitable allocation is easier said than done.

To figure out how to allocate gains and losses, the difference between each partner’s book basis and tax basis must be tracked. Then, apply a formula to allocate the income in a way that decreases each partner’s disparity as much as possible.

The hedge fund allocation process

This is the basis of what happens during the hedge fund allocation process:

  1. Ordinary income and expenses are allocated based on ownership percentages.
  2. “Stuffing” is performed for partners with full and partial withdrawals.
  3. Book basis is compared to tax basis, and realized gains and losses are allocated based on this disparity.
  4. Unrealized gains make up the difference between book and tax allocations.

Stuffing attempts to match book and tax gains for partners that are withdrawing from the fund. It’s the process of replacing the unrealized gains of partners exiting the fund with realized gains.

Upon withdrawal of a partner, all its gains and losses become realized. As such, a partner’s total unrealized gains over the life of the fund should net to zero upon withdrawal. Stuffing calculates that net unrealized amount and replaces realized gains and losses for any unrealized portion the partner would otherwise be allocated in that year.

This allocation calculation must reset every time capital is moved. Each period between capital transactions is deemed a break period. Break periods can arise from any event that affects the partners’ ownership percentages, including performance allocations, capital transfers between partners, or contributions and distributions.

Other considerations for hedge fund allocations

Other factors can influence hedge fund allocations, too. Those include performance allocation and other incentive arrangements, in-kind redemptions, built-in-gains from contributed securities and disallowed losses. In addition, hedge fund managers can allocate on the full or partial aggregate method.

How Wipfli can help

Still have questions? The professionals at Wipfli understand all of the moving parts associated with hedge funds. We can see through the complexity and help you make sense of hedge fund balances, allocations and tax requirements. Contact us today to learn more.

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Author(s)

Sarah K. Williams, CPA
Senior Manager
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