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

SKU: TAX1500 Back to Course Listings

Wyoming CLE
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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.

Lecturer Bios

David Schulder, Esq.

David Schulder works closely with clients to structure transactions to achieve the most favorable tax results. His practice encompasses all aspects of federal, state, local and international taxation, with an emphasis on onshore and offshore investment funds, venture capital transactions, corporate acquisitions, financial instruments and real estate acquisitions and dispositions.

Michele Gibbs Itri, Esq.

Michele K. Gibbs works closely with clients to structure transactions to achieve that most favorable tax results. Her practice encompasses all aspects of federal, state, local and international taxation, with an emphasis on onshore and offshore investment funds, venture capital transactions, corporate acquisitions, financial instruments and real estate acquisitions and dispositions.

Financial Services Matters: Michele assists clients in the structuring of onshore and offshore investment funds (such as general equity funds, fund of funds, distressed debt funds, arbitrage funds and global macro funds).

Corporate Matters: Michele assists clients in the structuring and organization of private partnerships and limited liability companies (primarily investment management and real estate management companies and start-ups).

Mark Strimber, Esq.

Mark Strimber is a principal who joined RSM from a Big Four firm’s international tax practice. Based in New York, Mark advises multinational corporations on the U.S. tax implications of their cross-border operations and reorganizations and is responsible for researching complex international and domestic tax issues for inbound and outbound transactions. Mark has assisted in planning tax-efficient structures for international transactions, tax due diligence and M&A transactions and reading and applying tax treaty provisions. He is an adjunct associate professor at Baruch College teaching international tax in the MST program.

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Accreditation and CLE Rules for Wyoming

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

Wyoming CLEAccreditation Info

About This Course

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