Blocker Structuring Under Current U.S. Tax Law: Key Considerations for U.S. Venture Funds and Their Investors
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax counsel and private investment professionals with a practical guide to structuring investments by private equity and venture capital funds (PEVC funds) in a manner that seeks to address the various tax sensitivities of PEVC fund investors.
Outline
- UBTI and UBIT impact of private equity, hedge fund, and offshore funds
- Blocker corporations
- Foreign vs. domestic structuring considerations
- Assets to hold in blocker corporations and capitalization issues
- Required filings
- Tax and operational risks
Benefits
The panel will review these and other noteworthy issues:
- U.S. PEVC fund activities that generate UBTI
- U.S. PEVC fund activities that generate ECI
- Consequences to investors of UBTI/ECI
- Blocker structures utilized by PEVC funds to mitigate the impact of UBTI/ECI
- How PEVC fund focus and strategy impacts optimal blocker structure
- Negotiation strategies for PEVC funds and their investors to ensure specific sensitivities are not overlooked
Faculty
Jace E. Clegg
Partner
Gunderson Dettmer Stough Villeneuve Franklin & Hachigian
Mr. Clegg's practice encompasses all areas of general corporate and partnership income taxation as well as the... | Read More
Mr. Clegg's practice encompasses all areas of general corporate and partnership income taxation as well as the taxation of mergers and acquisitions (both domestic and cross-border). He is broadly experienced with partnership taxation and has worked on numerous matters involving structuring tax efficient commercial and transactional structures for our corporate clients. Additionally, Mr. Clegg's practice focuses on the formation and general representation of venture capital and private equity funds and related entities.
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Brian D. Huber
Partner
Gunderson Dettmer Stough Villeneuve Franklin & Hachigian
Mr. Huber supports venture capital and growth equity fund managers on all aspects of the fund lifecycle. He has... | Read More
Mr. Huber supports venture capital and growth equity fund managers on all aspects of the fund lifecycle. He has significant experience advising fund managers on issues related to fundraising, GP management, and economics, including the tax and structuring aspects of fund formations and investments globally. He helps clients navigate complex matters in the evolving legal and regulatory landscape, such as the impact of recent tax reform on investment and organizational decision-making. He also has significant experience advising fund managers and investors in connection with secondary purchases and sales of fund interests.
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T. Tina Xu
Associate
Gunderson Dettmer Stough Villeneuve Franklin & Hachigian
Ms. Xu's practice encompasses all areas of general corporate and partnership income taxation as well as the... | Read More
Ms. Xu's practice encompasses all areas of general corporate and partnership income taxation as well as the taxation of mergers and acquisitions (both domestic and cross-border). She is broadly experienced with partnership taxation and has worked on numerous matters involving structuring tax efficient commercial and transactional structures for fund and corporate clients. Additionally, her practice focuses on the formation and general representation of venture capital and private equity funds and related entities.
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