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Capabilities

Investment Funds

Overview

Sadis' Tax group possess extensive experience and comprehensive perspective in federal, state, local and international tax matters, including planning and strategy advisement as well as in tax dispute resolution.

Sadis’ Tax group is relied upon by private investment funds to assist with the significant tax implications of the highly complex trading strategies and financial instruments they employ. We advise hedge funds, private equity funds, venture capital funds, foreign investors, fund managers and investors and U.S. tax-exempt organizations, including IRAs and foundations. These clients find our lawyers’ experience in planning and strategies involving international tax issues of particular value.

We have established many fund vehicles in offshore jurisdictions to achieve tax-efficient investing by both U.S. tax-exempt organizations and foreign investors. These structures are designed to accomplish the optimal lawful tax results for the participants, including minimization of United States taxation of foreign investors, and elimination of the Unrelated Business Income Tax (UBIT) for U.S. tax-exempt investors. In advising on offshore vehicles, we work closely with leading law firms established in the principle offshore jurisdictions, so as to achieve the optimal tax results in all of the tax jurisdictions involved.

We advise many fund managers on investment structuring and their rights to future profits or fees, in both onshore and offshore funds, to reduce taxation to the lowest possible levels.

 

Investment Funds Tax Group FAQs

What types of clients do Sadis's Investment Funds Tax Group serve?

Sadis's Investment Funds Tax Group advises hedge funds, private equity funds, venture capital funds, foreign investors, fund managers, and U.S. tax-exempt organizations, including IRAs and foundations, on the significant tax implications of complex trading strategies and financial instruments.

 

How does Sadis advise on tax-efficient offshore fund structures?

Sadis has established many fund vehicles in offshore jurisdictions designed to achieve tax-efficient investing for both U.S. tax-exempt organizations and foreign investors. These structures are designed to minimize U.S. taxation of foreign investors and eliminate Unrelated Business Income Tax (UBIT) for U.S. tax-exempt investors. The firm works closely with leading law firms in key offshore jurisdictions to achieve optimal tax results across all relevant tax jurisdictions.

 

Who advises on tax-advantaged structures for fund managers?

Sadis advises many fund managers on investment structuring and their rights to future profits or fees, in both onshore and offshore funds, to reduce taxation to the lowest possible levels. This includes carried-interest structuring, management fee arrangements, and co-investment planning.

 

Does Sadis advise on UBIT planning for tax-exempt investors in funds?

Yes. Sadis has extensive experience structuring offshore fund vehicles specifically designed to eliminate or minimize Unrelated Business Income Tax (UBIT) exposure for U.S. tax-exempt investors, including pension funds, endowments, foundations, and IRAs investing in hedge funds and private equity funds.

 

Can Sadis assist with tax planning for foreign investors in U.S. funds?

Yes. Sadis advises foreign investors on U.S. tax considerations arising from investments in domestic funds, including FIRPTA withholding, effectively connected income analysis, blocker structures, and treaty-based planning to minimize U.S. tax exposure.

Practice contacts

Seth Lebowitz's headshot
Partner
A.J. Alexis Gelinas's headshot
Counsel

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