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Accommodating Non-U.S. Investors: Structuring Real Estate and Other Fund Investments to Minimize U.S. Tax Impacts

SKU: TAX1500
Total Credits
1.5 - 1.8
Price$75
  • Online Access
  • Smartphone
  • iPad/iPod/Tablets
  • CDs/DVDs

Description

Tannenbaum Helpern tax attorneys Michele Itri and David Schulder along with RSM US LLP's International Tax Principal Mark Strimber, will discuss how hedge funds and private equity funds can minimize tax burden for non-U.S. investors. These investors are primarily concerned with avoiding U.S. tax filing obligations and paying U.S. tax on "effectively connected income" which can result from a non-U.S. investor's investment in U.S. real estate, certain U.S. loans, U.S. operating companies and fee participations. More information includes certain blocker structures and other techniques that can be used to accommodate these concerns and minimize the U.S. tax drain on the investment returns of non-U.S. investors.

Lecturer Bios

David Schulder, Esq.

David Schulder works closely with clients to structure transactions to achieve the most favorable tax results. His practice encompasses all aspects of federal, state, local and international taxation, with an emphasis on onshore and offshore investment funds, venture capital transactions, corporate acquisitions, financial instruments and real estate acquisitions and dispositions.

Michele Gibbs Itri, Esq.

Michele K. Gibbs works closely with clients to structure transactions to achieve that most favorable tax results. Her practice encompasses all aspects of federal, state, local and international taxation, with an emphasis on onshore and offshore investment funds, venture capital transactions, corporate acquisitions, financial instruments and real estate acquisitions and dispositions.

Financial Services Matters: Michele assists clients in the structuring of onshore and offshore investment funds (such as general equity funds, fund of funds, distressed debt funds, arbitrage funds and global macro funds).

Corporate Matters: Michele assists clients in the structuring and organization of private partnerships and limited liability companies (primarily investment management and real estate management companies and start-ups).

Mark Strimber, Esq.

Mark Strimber is a principal who joined RSM from a Big Four firm’s international tax practice. Based in New York, Mark advises multinational corporations on the U.S. tax implications of their cross-border operations and reorganizations and is responsible for researching complex international and domestic tax issues for inbound and outbound transactions. Mark has assisted in planning tax-efficient structures for international transactions, tax due diligence and M&A transactions and reading and applying tax treaty provisions. He is an adjunct associate professor at Baruch College teaching international tax in the MST program.



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