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

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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.

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