Funds

Fund managers in Europe are attracted to the capital potentially available from US-based investors, but they may be wary of the additional structuring and reporting requirements.

US investors may be concerned about the type of investments the funds are making, including whether they are regarded as Passive Foreign Investment Companies (PFICs) for US tax purposes. Or they may be concerned with any leverage that the funds take on in making acquisitions and whether this creates unrelated business taxable income (UBTI). CFOs of funds that already have US investors are concerned about the rising cost of US reporting and the timely delivery of reporting to their investors. They also like to have access to US advice in assessing the impact of potential transactions on US investors.

USTAXFS offers its clients a fee-sensitive and efficient US tax compliance solution while ensuring they meet fund and investor US tax reporting requirements on time.

Whether you are looking to establish a new fund, raise new capital, satisfy compliance reporting requirements, or plan an exit, we provide a customized service at every stage of a fund’s lifecycle. We also work with a network of law firms that provide legal services in setting up funds and other considerations, such as marketing.

We work with many different types of funds:

• Private Equity
• Venture Capital
• Real Estate
• Infrastructure
• Private Debt / Credit

Our Advisory Services

• Investment structure (equity vs. debt)
• Exit strategy planning
• Limitations on attributes (deductibility of losses)
• Buy-side due diligence (tax exposures)
• Assisting the fund with its obligations under FATCA & CRS
• Partnership Representative services

Our Compliance Services

Investment Funds with US investors and/or US investments may have extensive US tax reporting requirements. To navigate the extremely complex US tax system, our dedicated team offers customized services including structuring, advice on including US investors, US tax compliance and support for a clean exit. We specialise in K-1 and K-3 reporting for investors, PFIC analysis and testing and CFCs (Controlled Foreign Corporations) reporting.

Dedicated team of fund-focused US tax professionals

The US remains an important market for finding investors and for US investments by European funds (in fact, any fund outside the US). To navigate the extremely complex US tax system, our dedicated team of highly experienced fund-focused US tax professionals offer customized services for every stage of a fund’s lifecycle. This includes structuring and advice on including US investors.

Contact us to discuss how we can help.