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Advanced Tax Strategies in Structuring Private Equity and Real Estate Investment Funds: Balancing Competing Interests

Recording of a 90-minute premium CLE/CPE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
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Conducted on Thursday, March 24, 2022

Recorded event now available

or call 1-800-926-7926

This CLE/CPE course will provide tax counsel and advisers with advanced guidance on structuring private equity and real estate investment funds. The panel will discuss critical considerations in light of proposed new tax laws and address fund manager and fund investor issues.


In structuring private equity and real estate funds, the competing tax preferences of different types of fund investors are critical. The different types include U.S. taxable, U.S. tax-exempt, U.S. government, non-U.S. taxable, non-U.S. pension funds, and non-U.S. sovereign investors. Fund structures can use "blockers", “Subsidiary REITs” and feeder funds to address these various interests and minimize U.S. taxes and tax filing obligations.

Our panel will outline structures typically used, taking into account the type of U.S.-based funds, such as standard private equity and U.S. real property.

Tax counsel must also understand current issues, such as FATCA for non-U.S. investment entities and investors, the impact of tax reform for both fund managers and fund investors, and carried interest rules.

The program will conclude with an overview of typical investment fund documents and tax provisions including fund PPM, subscription agreement, and side letters.

Listen as our authoritative panel of practitioners provides a high-level analysis of the different and competing tax preferences of fund investors and fund managers and outlines sophisticated best practices for structuring investment funds to accommodate the myriad interests of these investors and managers.



  1. The impact of tax reform
  2. Tax objectives of taxable U.S. investors
  3. Tax objectives of non-taxable U.S. investors (pension plans, endowments, other tax-exempt investors, and governmental entities)
  4. Tax objectives on non-U.S. investors
  5. Tax objectives of sovereign investors
  6. Tax objectives of fund managers
  7. Fund structuring issues and options


The panel will review these and other vital questions:

  • What are the competing tax preferences of major private fund investors that practitioners must juggle when structuring investment funds?
  • How can the use of blockers, subsidiary REITs and feeder funds accommodate the needs of particular investors?
  • What challenges do sovereign investors face in retaining their status as Section 892 investors?
  • How do new tax rules impact tax planning when structuring private investment funds?


Hung, Shiukay
Shiukay Hung

DLA Piper

Mr. Hung is Partner and Co-Chair of DLA Piper’s National REIT Tax Practice. He advises public and private REITs...  |  Read More

Kim, Sharon
Sharon Kim


Ms. Kim advises the firm's leading financial institution and investment fund clients and investors on the U.S. tax...  |  Read More

Pae, JoonBeom
JoonBeom Pae

Mayer Brown

Mr. Pae's practice focuses on the tax aspects of the formation, financing and investment activities of domestic and...  |  Read More

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Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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