In this podcast, Laurel FitzPatrick, Adam Greenwood and Jim Brown discuss the tax considerations applicable to non-US investors investing in funds that invest in credit and debt instruments. So-called 'treaty funds' offer one alternative to managing tax implications resulting from these investments, but their complexity requires an understanding of the various structures and mechanisms of these types of funds. In particular, the group discusses the types of treaty funds that are available, such as ‘bring your own treaty’ and Luxemburg and Irish company structures, as well as the differences in operating a treaty fund versus a traditional private equity fund.
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