Accommodating Non-U.S. Investors: Structuring Real Estate and Other Fund Investments to Minimize U.S. Tax Impacts

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New Hampshire MCLE
Accreditation Info

New Hampshire attorneys must self-determine whether a program is eligible for credit and self-report their attendance. The United Institute for Continuing Legal Education believes that its courses meet the requirements of NH Supreme Court Rule 53 and qualify towards the annual NHMCLE requirement. To view our full accreditation details please .

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About This Course

This CLE course will explain the process by which both hedge funds and private equity funds may minimize the tax burden for non-US investors. Presented by Michelle Itri and David Schulder, tax attorneys at Tannenbaum Helbern as well as RSM US LLP’s International Tax Principal Max Strimber, the course will focus on legal avenues to avoid US tax filing obligations on what is called effectively connected income. The term typically applies to an investment made by a non-US citizen in US real estate, specified US loans and fee participation in US operating companies. The course will describe blocker structures and other techniques to minimize US tax obligations on the returns of non-US investors.
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