Taxation

  • Providing advice to investment adviser clients and the investment vehicles they manage as it relates to broker-dealer IRS tax reporting of their respective U.S. and non-U.S. investors;
  • Providing guidance to investment adviser clients and the investment vehicles they manage as it relates to broker-dealer account opening;
  • Providing advice regarding the applicability of the prohibited transactions provisions of the IRC to specific fund transactions;
  • Advising fund managers and investors as to the consequences of making contributions to investment vehicles from IRA assets;
  • Performing a tax election on behalf of a non-U.S. company to be treated as a U.S. partnership for tax purposes;
  • Performing a tax election on behalf of a non-U.S. limited partnership to be treated as a U.S. corporation for tax purposes; and
  • Establishing "master-feeder" structures to accommodate the tax concerns of both U.S. investors and non-U.S. investors investing in a single portfolio.