Qualified Matching Service for Hedge Funds Avoids Established Securities Market Designation and Corporate Treatment

摘要

In PLR 200507001, the taxpayer requested rulings that certain services were not established securities markets under Section 7704, and that one of the services was a qualified matching service under Reg. 1.7704-1(g). If the Service granted these requests, which it did, the taxpayer also requested that partnerships whose interests were offered on the services would not be publicly traded as a result of these offerings. The latter ruling was also granted, providing the representations were correct.