Funds

June 5 EVENT | Foreign Funds Investing or Operating in the United States – Key Tax, Regulatory, and Immigration Updates


Please join GT Shareholders Kate Kalmykov, Erez Tucner, and Cynthia Marian for the next lunch-and-learn.

The program will discuss:

U.S. Tax Considerations

Key U.S. tax considerations for foreign funds investing or operating in the United States

  • U.S. trade or business income
  • Dividends from U.S. corporations
  • Interest from U.S. holding or portfolio companies or U.S. third-party borrowers
  • Capital gains from sale of U.S. portfolio companies and FIRPTA

Key relevant U.S. tax updates

  • YA Global Tax Court decision (Nov. 15, 2023)
  • Soroban Capital Partners Tax Court decision (Nov. 28, 2023)
  • U.S. – Chile income tax treaty (Dec. 19, 2023)

U.S. Regulatory Considerations

Key U.S. regulatory considerations for foreign funds investing or operating in the United States

  • U.S. Securities Laws, including the Investment Company Act of 1940 (the “’40 Act”) and the Investment Advisers Act of 1940 (the “Advisers Act”)
  • Soliciting and marketing to U.S. investors
  • Regulatory implications of U.S. offices or personnel
  • Foreign Private Adviser Exemption
  • Exempt reporting adviser qualification and obligations
  • Blue sky filings

U.S. Immigration Considerations

Key U.S. immigration considerations for foreign funds transferring principals and employees to the United States

  • Developing a U.S. immigration strategy
  • L-1A multinational manager and executive visa
  • E-2 Treaty Investor Visa

Location:

The lunch-and-learn program will take place in-person at Greenberg Traurig’s NYC office in One Vanderbilt on Wednesday, June 5 at 12 – 2:00 p.m. ET.



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