Webinar - European Funds with US Connections - Update on the US Tax Environment

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.