Tax Challenges With U.S.-Based Private Equity Fund Formation
Maximizing Benefits for Clients Given Diverse Investor Tax Objectives
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisors with a summary of basic fund prototypes, a comprehensive review of the principal U.S. tax objectives of the general partner and the fund manager, and explain the various categories of investors in a typical fund and location of fund.
Outline
- Tax objectives of taxable U.S. investors
- Tax objectives of non-taxable U.S. investors (pension plans, endowments, other tax-exempt investors and governmental entities)
- Tax objectives on non-U.S. investors
- Tax objectives of sovereign investors
- Tax objectives of fund managers
- Fund structuring issues and options
- Impact of NII Tax
Benefits
The panel will review these and other key points:
- The impact of the American Tax Relief Act of 2012.
- How the 3.8% Medicare tax can be minimized.
- Structures for U.S. investors investing in U.S. and non-U.S. based funds.
- Alternative approaches to both common and unique tax scenarios for tax professionals who regularly advise private equity funds and their investors.
Faculty

Joshua V. Azran
Owner
Azran Financial
Mr. Azran has expertise in public accounting, corporate finance, strategic management, financial restructuring,... | Read More
Mr. Azran has expertise in public accounting, corporate finance, strategic management, financial restructuring, business valuation, management consulting, and business development. He is also a lecturer in the College of Business Administration at Loyola Marymount University in Los Angeles and spends time serving on the boards of several charitable and professional organizations.
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David Benz
Principal
Rothstein Kass
Mr. Benz is a principal in Rothstein Kass’ Private Equity practice. He specializes in partnership taxation,... | Read More
Mr. Benz is a principal in Rothstein Kass’ Private Equity practice. He specializes in partnership taxation, with a concentration on the private equity, commercial real estate and public utilities sectors. He has 20 years of experience in taxation of partnerships, limited liability companies, Subchapter S corporations and related offerings.
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