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”)
Rarely does a tax opportunity arise in a private equity and investment group of this caliber. This tax opportunity is a rare and hidden secret and great success story in San Francisco, CA.
TaxConnections has been retained by an investment group to locate an Assistant Tax Manager responsible for assisting the Director of Tax, Pass-Through Entities and the Senior Tax Manager in managing the tax planning and compliance functions for multiple business lines and other investments owned by family.
Primary emphasis is on tax compliance, planning, and support for pass-through entities. Understand and apply the current tax laws and regulations including the tax implications of investment partnership structures and real estate development and operations. Identify and communicate issues, positions, and opportunities both orally and in writing to management. Manage members of the tax accounting staff.
Responsibilities include the following:
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:
TaxConnections Executive Search Services Division has been retained to conduct a search for a Senior Vice President Tax in the Los Angeles, CA area. This client has a global diversified portfolio of investments including real estate and varied business holdings.
An ideal Senior Vice President Tax candidate will be currently working as a Partner in a Big Four firm, real estate investment firm, investment fund, private equity or asset management.
Senior Vice President Tax
Responsibilities include global tax strategy, tax planning and compliance; review and filing of all domestic and international corporate, personal, partnership and other income and indirect tax returns; and implementing and managing company’s income tax and indirect tax compliance activities (partially insourced and partially outsourced); and supervision of an outstanding, incumbent tax team. The Senior Vice President Tax will work directly with the CFO in identifying and developing effective tax strategies and planning techniques to minimize overall tax burden of consolidated group of companies and minimize overall costs associated with the tax structure. The Senior Vice President of Tax will lead acquisition structuring and due diligence including tax integration efforts.