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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Thursday, May 15, 2025

  • schedule Time

    1:00 PM E.T.

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

$347.00
CLE
ALL

This CLE/CPE webinar will provide tax counsel and advisers with guidance on navigating tax implications of non-U.S. investment in U.S. private credit funds. The panel will discuss common fund structures designed to accommodate non-U.S. investors and certain related tax considerations and consequences to non-U.S. investors. The panel will also review critical factors, such as type of investor, structure of fund, and location of fund, and address fund and investor tax issues.

Faculty

Janicelynn Asamoto Park
Attorney
Proskauer Rose LLP

Ms. Park counsels fund managers and investors on the tax and economic consequences of forming, operating, and investing in domestic and international private investment funds. She also advises on domestic and cross-border financings and investments, and inbound and outbound private mergers and acquisitions.

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Christine Harlow
Partner
Proskauer Rose LLP

Ms. Harlow is a partner in the firm’s Tax Department and a member of the Private Funds Group, advising clients on the tax aspects of private funds, including hedge funds, credit funds, private equity funds and joint ventures. She represents private fund managers in the formation of private funds, ongoing operations and the tax consequences of purchasing and disposing of investments. Ms. Harlow also represents investors regarding the tax consequences of investing in private funds. She advises fund managers and investors on a variety of fund structures, including closed-end, open-end, hybrid, and evergreen. Ms. Harlow's experience also includes structuring and negotiating seed and strategic investments and advising private fund managers with respect to the sale of investment management and general partner entities.

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Description

The United States remains a popular destination for investments by non-U.S. investors. Non-U.S. persons investing in U.S. private credit markets, funds, and related entities must understand the tax consequences arising from the various structures used to invest in the United States.

For income tax purposes, non-U.S. investors must balance various tax issues to determine the appropriate ownership vehicle for U.S. investments. Various ownership structures--whether direct ownership by a non-U.S. person or use of a U.S. or non-U.S. corporation, partnership or other vehicle--each have particular income tax consequences for the non-U.S. owner. Because non-U.S. investment in U.S. assets is a highly tax-driven activity, advisers must be well-versed in the tax consequences of various structures, plus the related tax compliance requirements.

Listen as our panel of tax practitioners goes beyond the basics to provide a comprehensive and practical guide to structuring foreign investment in U.S. private credit, from ownership profile through finalizing the deal.

Outline

  1. Persons subject to U.S. taxation
  2. U.S. taxation of foreign persons
  3. Advantages and disadvantages of alternative investment structures
  4. Tax strategies

Benefits

The panel will review these and other key issues:

  • What are the various tax consequences of a non-U.S. person owning U.S. loans or originating loans directly?
  • What exceptions or safe harbors are available for non-U.S. investors?
  • What are common structures used for funds investing in U.S. private credit?
  • What is the impact of blocker corporations and other intermediary entities on the tax treatment of foreign investment in U.S. private credit?