Blank Rome tax attorneys have substantial experience in the representation of private and publicly registered investment funds. They have, with respect to hundreds of funds, provided advice to fund sponsors, fund investors, and principals of fund sponsors.
This experience gives them a thorough understanding of the tax and the business issues of this practice area, and allows them to provide practical and highly knowledgeable legal service.
They have provided services to mutual funds, closed-end investment companies, hedge funds, real estate funds, private equity funds, venture capital funds, mezzanine funds, distressed debt funds, and lending funds. They are experienced in cross-border fund structures, including inbound investment into U.S. funds by non-U.S. investors, and outbound investment in non-U.S. fund by U.S. investors.
Our tax attorneys have extensive experience with master-feeder structures, private REITs, complex distributions and capital account allocations, the design of carried interests for both funds and general partners (including with vesting provisions), management fee waivers, capital gains “cherry-picking”, management fee expenses, clawbacks, private REITs, alternative investment vehicles, UBTI planning (including “fractions rule” funds), passive foreign investment companies, offshore lending, and more.
They have been involved in designing unique fund structures for specialized investment programs, which may involve hybrid funds combining features of hedge funds and of private equity funds.
Our tax attorneys have also done a great deal of work representing institutional investors, both taxable and tax-exempt, with respect to the tax issues relating to alternative investments in private investment funds. We also provide a very efficient review of fund documents for such investors, and have extensive experience in dealing with fund sponsors and their counsel. The goal is to secure appropriate drafting of such documents and to ensure investors are realizing the expected economic terms and being provided with appropriate legal protections.