Tax Treatment of Leveraged Blockers Used by Foreign Investors: Recent IRS Guidance, Deal Structures, Tax Planning
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. assets utilizing leveraged blockers and other tax planning mechanisms. The panel will discuss recent IRS guidance, key tax considerations in structuring deals involving foreign investors, transfer pricing analysis, and other key items.
Outline
- Blocker structure variations and choice of entity
- Potential income and estate tax issues
- Mitigating ECI exposure
- Recent IRS Transfer Pricing Memo
- Examples and additional strategies for tax efficiency
Benefits
The panel will discuss these and other key issues:
- Income tax consequences of investing in U.S. assets through a foreign corporation
- How can leveraged blockers be used to mitigate the impact of ECI?
- Recent IRS Transfer Pricing Memo
- Best practices for tax professionals structuring leveraged blockers
Faculty
Paul Flignor
Principal Economist
DLA Piper
Mr. Flignor concentrates his practice in intercompany pricing and intellectual property valuation.
Mr.... | Read More
Mr. Flignor concentrates his practice in intercompany pricing and intellectual property valuation.
Mr. Flignor has more than 15 years of professional experience in resolving pricing and valuation issues in the areas of international tax planning, controversy resolution, transaction support, licensing and financial economics. He is noted particularly for integrating business strategy and financial economics to solve complex valuation problems of leading companies.
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Shiukay Hung
Partner
DLA Piper
Shiukay Hung is a Partner and the Co-Chair of DLA Piper’s National REIT Tax Practice. He is recognized as a... | Read More
Shiukay Hung is a Partner and the Co-Chair of DLA Piper’s National REIT Tax Practice. He is recognized as a leading tax lawyer by both Chambers USA and Legal 500. Shiukay’s tax practice primarily focuses on REITs and real estate private equity, including real assets credit and mortgage REITs. His clients include Canadian pension funds, sovereign wealth funds (SWFs), US sponsors, US-listed REITs, and non-traded REITs.
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Neeraj Kirpalani
Senior Managing Economist
DLA Piper
Mr. Kirpalani provides a range of transfer pricing services with a focus on intercompany financing. He has... | Read More
Mr. Kirpalani provides a range of transfer pricing services with a focus on intercompany financing. He has experience with clients across a variety of industries including financial services, energy, consumer products, apparel, and pharmaceuticals.
Mr. Kirpalani advises clients by gathering quantitative and qualitative information on the client's business and industry, conducting functional and financial analyses of companies' operations and preparing transfer pricing planning and documentation studies to comply with domestic and OECD taxation regulations.
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Aalok Virmani
Partner
DLA Piper
Mr. Virmani advises investment fund sponsors on federal income tax matters. In particular, he focuses on the domestic... | Read More
Mr. Virmani advises investment fund sponsors on federal income tax matters. In particular, he focuses on the domestic and international tax aspects of forming, organizing, and operating private equity funds, private equity real estate funds, venture capital funds, hedge funds, debt funds and secondary funds. Mr. Virmani's practice includes counseling family offices with respect to establishing investment platforms and management incentive arrangements. He also regularly represents clients with respect to GP-led fund restructurings, U.S. and non-U.S. investor representations, secondary transactions, and minority investments in fund sponsors. Mr. Virmani spent significant time in-house as a principal at Equity International, a private equity firm that invests in non-U.S. real estate companies.
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