Leveraged Blockers for Foreign Investors: Tax Implications
U.S. Nonresident Taxation, Structuring Considerations, Weighing Tax Consequences, Alternative Investments
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will discuss how a leveraged blocker corporation can maximize net returns to non-U.S. investors and minimize U.S. reporting requirements. Our panel of global structuring experts will review the benefits of leveraged blockers, calculating the tax benefits, and alternative structures that international tax advisers should sometimes consider.
Outline
- Leveraged blockers: introduction
- U.S. taxation of nonresident investors
- Benefits of leveraged blockers
- Structuring a leveraged blocker corporation
- Transfer pricing analysis
- Caveats and other considerations
- Alternative investment options
Benefits
The panel will review these and other critical issues:
- U.S. taxation of nonresidents
- Foreign investors and situations that are ideal candidates for leveraged blockers
- Alternative investment options when a leveraged blocker corporation is not ideal
- Weighing the benefits and caveats of a leveraged blocker structure for specific foreign investors
Faculty
Brett Fieldston
Principal
KPMG
Mr. Fieldston is a Principal in KPMG’s International Tax group, specializing in asset management and... | Read More
Mr. Fieldston is a Principal in KPMG’s International Tax group, specializing in asset management and investment funds. He advises U.S. and global asset managers on investment and investment fund structuring, as well as management companies, with respect to a wide-spectrum of cross-border and U.S. international taxation issues.
Close
Jay Freedman
Principal
KPMG
Mr. Freedman is a Principal in KPMG’s Financial Services Tax Practice, and serves as the firm’s Global... | Read More
Mr. Freedman is a Principal in KPMG’s Financial Services Tax Practice, and serves as the firm’s Global Industry Leader for the firm’s Hedge Fund Tax Practice. For over 30 years, he has focused on a broad array of tax issues, across financial products and derivatives, cross-border structuring and transactions, partnership tax, and corporate tax, with an emphasis on issues related to the alternative investment and banking industries. Mr. Freedman has significant experience in both tax consulting and tax compliance and regularly advises clients on tax planning for structuring funds and portfolios. He offers clients an experienced perspective, having served in several senior-level in-house positions at major organizations in the international investment manager, securities dealer, and investment bank sectors, and is able to offer both buy-side and sell-side perspectives. Mr. Freedman is a member of the board of directors of the Wall Street Tax Association, as well as a past-president and past-chairman of its Federal Tax Committee. He is also a member of the Managed Funds Association Tax Committee and has participated in a number of industry group efforts through the Securities Industry and Financial Markets Association and the International Swaps and Derivatives Association. Mr. Freedman is a frequent speaker on topics that include alternative investments, financial products, and other tax issues related to the financial services industry and is a co-author of KPMG’s Derivatives Tax Handbook.
Close
Sam Riesenberg
Partner
Mayer Brown International
Mr. Riesenberg has significant experience with private credit, private equity, M&A, fund formation,... | Read More
Mr. Riesenberg has significant experience with private credit, private equity, M&A, fund formation, infrastructure funds, investment structuring and tax issues involving asset management and operational activities, with a client base comprising fund sponsors, sovereign wealth and pension funds, institutional investors, family offices and fund managers. Clients turn to Mr. Riesenberg for advice in the areas of asset management and fund matters across the US, Europe, and the Middle East.
Close
