Investment structuring

Our personal tax team advises individuals on the tax treatment and structuring of a broad range of financial and other investments, including sophisticated structured products and derivatives.

Although we do not provide investment advice, by considering how investments are structured and taxed, we assist our clients in choosing the type of investment to buy considering the needs of particular clients, cross-border issues, taxation efficiency, and regulatory requirements.

In addition to offering advice as to the effect of their direct investment, we advise our clients on structuring their investments through the use of a partnership or corporate vehicle or a trust so as to achieve a better tax position. We also advise funds and other investment managers on all aspects of investment structuring, taking into account the tax issues affecting the target investor including the type of investment, the type of holding structure and how funds are invested or distributed.

Recent work

  • Working with a Wall Street entrepreneur to establish and structure his private equity fund. We assisted him in the initially planning and structuring of the fund and prepared offer documents and constitutional documents. Along the way our team provided all the requisite advice on the salient United States tax and regulatory issues.
  • Advising a Greenwich fund manager on various employment packages for her small but growing organization. In order to retain talent, she hired our firm to structure deferred compensation packages which allowed employees an equity stake in the firm while minimizing their taxes.
  • Advising a US based family who invested together on a "pooled basis". Even though both parents had died recently, the offspring of the family wanted to continue to invest in both real estate and hedge funds, but in varying percentages. Our lawyers structured "tracking partnerships" which allowed the family to continue to invest together but in different asset classes and monetary commitments.
  • Advising a multinational family on the tax efficient structuring of investments across multiple jurisdictions.

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