Hedge, private equity & other investment funds

We work with a wide range of private investment funds, including hedge funds, private equity funds, real estate funds, funds of funds, commodity pools and distressed debt funds, to create tax-efficient structures for both investors and fund managers.

Our work includes drafting and negotiating all relevant fund offering, subscription and organizational documents. Our clients include both domestic US funds and offshore funds, so naturally we also deal with regulatory compliance in many relevant jurisdictions.

Additionally, we advise on qualified and non-qualified deferred compensation arrangements for the fund principals and their employees. We also counsel principals on the gift and estate tax planning opportunities available to them as the founders and owners of such funds.

Recent work

  • Working with 7 principals of a $1+ billion private equity fund to structure the tax-efficient transfer of their interests in a new fund to wealth transfer vehicles
  • Working with a principal of a $1+ billion distressed debt fund to establish a private foundation and contribute interests in the fund's general partner in a manner that permitted the principal to claim a fair market value deduction
  • Advised the Trustees of a substantial charitable remainder trust regarding unrelated business income tax issues arising from proposed fund investments
  • Advised large Middle East-based insurance company with respect to its investment in US real estate fund
  • Advised large non-US family office on tax efficient structures for investments in US real estate, businesses and portfolio assets.

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