Taxation of Non-U.S. Investment in U.S. Private Credit Funds: Fund Structures, Tax Rules, Exceptions, Safe Harbors

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.

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.