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OVERVIEW:
The aim of the session was to provide insight into the additional reporting and compliance requirements that come with accepting US investors or investing in US assets and to de-mystify some of the jargon surrounding it. The intention was also to provide insight into the latest Biden tax changes and their impact on funds.
Who was it aimed at:
- People in finance or tax roles with European LP funds that have, or are targeting, US investors or that are investing in US assets.
- Fund administrators, lawyers or local tax advisers whose fund clients have US connections
Topics that were covered:
- How do I structure my fund to accept US investors?
- What is a PFIC, and who needs to know?
- Who needs a K-1, and how do I provide one?
- Does the fund ever have to file in the US if there are no US investments?
- Will my fund be generating UBTI, and why does this matter?
- Changes to the rules for reporting partner capital accounts
- How do my European investors get returns paid on time from US exits?
- What is the role of a Partnership Representative, and do I need one?
- How is the fund or the investors affected by Biden tax changes to carried interest and capital gains rates?
Speaker: Bradley Albin
International Corporate Tax Director
Bradley Albin is from US Tax & Financial Services, a boutique firm based in London, Geneva, Zurich and Berlin, that specialises in US tax compliance and planning.