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Private Equity: Offshore Investments And Phantom Income

Private equity funds pool capital for investment in privately-held businesses. Increasingly, PE funds are looking to global investment markets and foreign opportunities.

Investors and fund managers generally share a number of common tax goals, including minimizing “phantom” income—that is, profit allocations that do not have a corresponding cash distribution.

In keeping with this goal, funds investing outside of the United States typically attempt to mitigate, if not avoid, U.S. anti-deferral regimes. Historically, the two most notable regimes in this respect are the Subpart F rules applicable to U.S. shareholders of “controlled foreign corporations” (CFCs) and the “passive foreign investment company” (PFIC) regime. In addition, the Tax Cuts & Jobs Act introduced another commonly encountered anti-deferral regime: global intangible low-taxed income (“GILTI”).

Controlled Foreign Corporations (“CFCs”)

Written by Jason Freeman | Posted in Controlled Foreign Corporation • Offshore Investments And Phantom Income • Private Equity

TaxConnections has recently been retained to conduct a search for a Senior Tax Specialist for a high profile family office in the San Francisco area. Rarely is a position available in this very rewarding business environment.

The Senior Tax Specialist is responsible for performing tax compliance and planning functions as well as providing tax support for various family entities, which may include Partnerships, Limited Liability Companies and Corporate entities. Significant emphasis will be on tax work related to Partnerships and Limited Liability Companies. Responsibilities include the preparation of federal and state income tax returns and forecasts and perform various tax planning and research projects that involve a high degree of complexity. Respond to audits and information requests from various government authorities.

Responsibilities include the following:

Written by TaxConnections Admin | Posted in Private Equity • San Francisco • Senior Tax Specialist