Private Equity Funds

Our team offers innovative and thoughtful approaches to the unique tax challenges faced by private equity funds and their managers.

Our deep experience working with and for fund managers of all types enables us to offer tailored advice to private equity funds based on the nature of their investors and investments —real estate centered funds and funds conducting cross-border investments are but two examples.

We advise our private equity clients in connection with:

  • Fund formation and structure
  • Acquisitions and dispositions
  • Structuring acquisitions to provide post-acquisition tax efficiencies
  • Management company planning, in particular relating to compensation practices
  • US tax implications of non-US investments, for example under the “CFC,” “PFIC” and foreign tax credit rules
  • Real estate investments, in particular relating to FIRPTA, and the use of REITs to address federal, state and local tax issues affecting U.S. taxable, U.S. tax exempt, and non-U.S. investors
  • Tax treaty planning, in particular relating to inbound U.S. investments by non-U.S. investors

Featured Insight

See More Insights