Blocker Corporation Structuring in Investment Funds: Tax and Other Considerations for Fund Investors
Avoiding UBTI and ECI; Entry and Exit Strategies
Note: CPE credit is not offered on this program
Recording of a 90-minute premium CLE video webinar with Q&A
This CLE course will provide fund counsel with the tools for structuring blocker corporation investments by investment funds, in particular private equity and venture capital funds (PEVC funds), in a manner that seeks to address the various tax sensitivities of PEVC fund investors.
Outline
- General overview of fund structures and investor types
- Overview of UBTI/ECI-generating activities and common fund strategies to mitigate UBTI/ECI exposure
- Blocker structure variations
- Practical tax considerations in employing blockers for and exiting portfolio investments
- Additional strategies for tax efficiency
Benefits
The panel will review these and other vital issues:
- What private investment fund activities result in UBTI or ECI?
- How can blocker corporations be used to mitigate the impact of UBTI and ECI?
- How does the investment strategy of the fund impact the blocker structure?
- How has tax reform and subsequent changes to tax law impacted the structural options available to private investment funds?
Faculty
Jace E. Clegg
Partner
Gunderson Dettmer Stough Villeneuve Franklin & Hachigian
Mr. Clegg's practice encompasses all areas of general corporate and partnership income taxation as well as the... | Read More
Mr. Clegg's practice encompasses all areas of general corporate and partnership income taxation as well as the taxation of mergers and acquisitions (both domestic and cross-border). He is broadly experienced with partnership taxation and has worked on numerous matters involving structuring tax efficient commercial and transactional structures for our corporate clients. Additionally, Mr. Clegg's practice focuses on the formation and general representation of venture capital and private equity funds and related entities.
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Brian D. Huber
Partner
Gunderson Dettmer Stough Villeneuve Franklin & Hachigian
Mr. Huber supports venture capital and growth equity fund managers on all aspects of the fund lifecycle. He has... | Read More
Mr. Huber supports venture capital and growth equity fund managers on all aspects of the fund lifecycle. He has significant experience advising fund managers on issues related to fundraising, GP management, and economics, including the tax and structuring aspects of fund formations and investments globally. He helps clients navigate complex matters in the evolving legal and regulatory landscape, such as the impact of recent tax reform on investment and organizational decision-making. He also has significant experience advising fund managers and investors in connection with secondary purchases and sales of fund interests.
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T. Tina Xu
Attorney
Gunderson Dettmer
Ms. Xu's practice encompasses all areas of general corporate and partnership income taxation as well as the... | Read More
Ms. Xu's practice encompasses all areas of general corporate and partnership income taxation as well as the taxation of mergers and acquisitions (both domestic and cross-border). She is broadly experienced with partnership taxation and has worked on numerous matters involving structuring tax efficient commercial and transactional structures for fund and corporate clients. Additionally, Ms. Xu's practice focuses on the formation and general representation of venture capital and private equity funds and related entities.
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