About the Course
Introduction
This CPE webinar will examine the tax and structuring considerations for private equity funds and hedge funds engaged in cross-border investments. Our accomplished panel of foreign tax advisors will explain how fund structures, investor classifications, and investment strategies drive U.S. and foreign tax consequences, reporting obligations, and planning opportunities for fund sponsors and investors operating globally.
Description
Private equity and hedge funds increasingly hold cross-border positions, raising complex questions about entity classification, withholding, effectively connected income, and treaty relief. Private equity and hedge fund sponsors commonly employ master-feeder arrangements, blocker corporations, and other structures to accommodate U.S. taxable investors and foreign investors. The selection of a particular structure can affect withholding obligations, treaty access, reporting requirements, effectively connected income exposure, and after-tax investment returns.
Listen as our panel of notable international tax attorneys offers practical guidance on structuring and compliance considerations for private equity and hedge funds with cross-border investments.
Presented By
Mr. Klug is a trusted attorney with extensive experience in taxation, corporate planning, mergers and acquisitions, and estate planning. With decades of experience advising clients on everything from corporate tax structuring and cross-border transactions to private equity, estate planning, and family office strategy, he brings a rare blend of big law pedigree and boutique, hands-on partnership.
Ms. Lee is a trusted tax advisor with extensive experience in navigating the complexities of U.S. tax law and tax treaties, offering strategic counsel to her clients in the areas of individual and business tax planning, compliance, and controversies, as well as domestic and international estate planning. She has been instrumental in facilitating new business entity formation and fund formation, ensuring that her clients remain compliant with corporate regulatory requirements. Ms. Lee is admitted to the California Bar and fluent in Korean.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
Date + Time
- event
Monday, November 16, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Private Equity Funds and Hedge Funds: An Overview
II. Investor types and tax considerations
III. Structures for Cross-Border Investments
IV. Foreign funds with U.S. investments
V. U.S. funds with foreign investments
VI. Tax compliance requirements
The panel will review these and other critical issues:
• Fundamental differences between private equity funds and hedge funds
• Structuring funds for U.S. and foreign investors
• Tax compliance and information reporting obligations for funds with cross-border activity
• Recognizing planning opportunities and common structuring pitfalls
Learning Objectives
After completing this course, you will be able to:
• Identify the key structural and tax differences between private equity funds and hedge funds
• Determine tax considerations applicable to different categories of fund investors
• Recognize common structuring approaches for funds with cross-border investment activity
• Ascertain U.S. tax implications for foreign funds investing into the U.S.
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite:
Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation, including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI/NCTI, Subpart F, and the related Section 250 deductions.
BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .
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