Private Equity Funds (Portfolio 735)

Description

Bloomberg Tax Portfolio, Private Equity Funds, No. 735, addresses the full range of U.S. tax issues that arise in the representation of private equity funds. The purpose of this Portfolio is to provide a source of guidance to tax practitioners who regularly advise private equity funds and their investors. It includes a description of basic fund prototypes, a discussion of common economic terms and variations thereon, and a comprehensive summary of the principal U.S. tax objectives of the general partner, the fund manager, and the various categories of investors in a typical fund.

Table of Contents

I. Introduction
II. Fund Prototypes
III. The Economic Deal
IV. Achieving Pass-Through Treatment for the Fund and its Affiliates
V. Tax Allocations
VI. Special Tax Issues for the General Partner and Its Members
VII. The Problem of ECI and UBTI
VIII. Special Issues with Convertible Debt Investments
IX. Withholding Taxes of Foreign Investors
X. U.S. Tax Objectives of U.S. Individual Investors
XI. Anti-Deferral Rules for Foreign Investments by Private Equity Funds
XII. Taking the “Private” Out of Private Equity — the IPO