Training session agenda
1. Getting the structure right from the outset
Structure of the fund (transparent vs opaque) and how this avoids PFIC issues for US investors
Managing US withholding and reporting risk for non-US investors (what "ECI" means, and how blocker structures help)
Structuring feeder vehicles for investors with both US and UK exposure
Common pitfalls to avoid
2. Where US and UK tax rules pull in different directions
Entities that are viewed differently for US and UK tax purposes, and why that matters
Timing issues associated with the taxation of carried interest and accrued election mechanics
Taxpayer mismatches
Foreign tax credit and treaty considerations
3. Staying on top of ongoing reporting
Schedule K-1 and K-3: what's required and when
PFIC, UBTI and CFC exposure within the fund, and what needs to flow through into K-1/K-3 reporting