US Tax Lawyer – Fund Transactions

Responsibilities Ensure U.S. tax compliance for the management of private equity funds, taking into account risk, operational, and tax considerations Continuously analyze U.S. tax legislation and assess its impact on portfolio investments and investors Review distribution provisions in fund agreements and determine distribution allocations for investors Analyze international tax rules for PFICs and CFCs and oversee U.S. tax reporting obligations (Forms 926, 8865, 8621, 5471, etc.) Advise on characterization of debt and equity, unrelated business taxable income (UBTI) for tax‑exempt clients, and other tax matters relevant to private equity funds Evaluate clients' investments for U.S. tax implications Provide investment‑related advice on the selection of U.S. tax structures Act as a single point of contact for tax‑related queries from internal and external stakeholders Monitor guidance and updates from U.S. tax authorities (including developments under the IRA) Work with IT to implement ...