Variable Trusts – Tax & Compliance

Gemini’s tax and compliance teams regularly monitor the industry in order to address client concerns and proactively recommend the actions needed to protect our client’s funds.

Tax Department Responsibilities
  • Dividend distribution review and determination for periodic paying funds
  • Providing clients assistance with tax planning for the fund
  • Tax and fiscal year-end tax provisioning, including return of capital adjustments
  • Preparation of year-end distribution estimates and distribution determinations
  • Preparation and review of tax disclosures
  • Reviewing and filing tax returns
  • Reviewing portfolio holdings for tax implications
  • Assisting new clients with the review regarding fund tax structure and fiscal year-end filing options.
  • Serving as a liaison with external parties (including the fund’s auditors and regulatory agencies) on behalf of clients
Compliance Administration Department Responsibilities
  • Automation of the Charles River compliance workflow
  • Providing centralized, post-trade compliance monitoring and management
  • Post-trade monitoring of SEC compliance, prospectus and SAI compliance, as well as IRS code compliance and support
  • Post-trade compliance testing:
    • Daily/weekly compliance review and notifications to clients, as applicable (daily monitoring is performed through Charles River, an automated exception-based monitoring system)
    • Month-end compliance reporting to clients including providing a summary of any monthly notifications
    • Quarterly summary of compliance issues for the Board
  • Monitoring a fund’s compliance with:
    • IRS diversification tests
    • IRS gross income test
    • 1940 Act requirements
    • Prospectus and SAI limitations
  • Creating a compliance checklist for newly launched funds
  • Performing operational calls to review procedures and compliance rules and interpretations
  • Reviewing prospectus and SAI updates on an ongoing basis to ensure testing stays current
  • Assisting new clients with the review of fund structure and strategy to ensure compliance under the various regulatory requirements
  • Reviewing portfolio holdings for compliance implications
  • Serving as a liaison with external parties (including the fund’s auditors and regulatory agencies) on behalf of clients