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An investment fund challenged an IRS determination that various contracts entered into between the fund and an investment bank resulted in the fund having effective ownership of the positions that were the subject of the contracts.

Commentary by Steven Lofchie

Researchers at the Office of Financial Research questioned the application of SEC Form PF as a risk-management instrument. In a published working paper, they recommended capturing additional characteristics on the form to "constrain the range of possible risk profiles more tightly," and suggested revamping the form to better represent complex portfolios.