Excerpt from Practical Guidance

A Primer On Effectively Connected Income

Law360, New York (May 18, 2017, 3:12 PM EDT) -- There are a handful of organizational structures that a U.S.-based private equity fund (sometimes referred to in this article as a fund) may utilize. Nonetheless, non-U.S. investors (sometimes referred to in this article as a foreign person or foreign investor) generally have common goals in making U.S. investments, namely:

Avoid having to file U.S. income tax returns and otherwise having their identity disclosed to U.S. tax authorities

  Avoid U.S. taxation on an exit event

  Avoid or minimize U.S. withholding taxes that may be imposed on cash flow from the United States

Against this backdrop, this article presents a brief...

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