Hedge Fund Managers May Be Required to File TIC Form SHC by March 2, 2012

Hedge fund managers should consider as soon as possible whether they are required to file Treasury International Capital (TIC) Form SHC, Report of U.S. Ownership of Foreign Securities, Including Selected Money Market Instruments.  Basically, Form SHC requires the reporting of information regarding foreign securities owned by U.S. residents.  A hedge fund manager is required to file Form SHC if it meets a $100 million threshold for “reportable securities” determined on an aggregate basis for all funds under management.  For 2011, Form SHC is due by March 2, 2012, and reporting is based on the fair value of assets determined as of December 31, 2011.  In a guest article, Philip Gross and Allison Bortnick, Member and Associate, respectively, at Kleinberg, Kaplan, Wolff & Cohen, P.C., discuss the parameters of Form SHC, including a discussion of who must file Form SHC and what securities are covered; the composition of Form SHC; and the approach that hedge fund managers may take to determine whether they must file Form SHC, and, if reporting is required, how to complete Form SHC.

To read the full article

Continue reading your article with a HFLR subscription.