TY - JOUR T1 - U.S. Tax Planning Considerations for Investments in Foreign Portfolio Companies JF - The Journal of Private Equity SP - 76 LP - 83 DO - 10.3905/jpe.2004.450954 VL - 8 IS - 1 AU - David M. Neuenhaus AU - Francis J. Helverson Y1 - 2004/11/30 UR - https://pm-research.com/content/8/1/76.abstract N2 - Foreign investment by U.S. funds is increasingly common. Foreign investment involves complex U.S. tax issues that differ from those encountered in the purely domestic context. This article provides a road map to help advisors and fund professionals better understand a number of the important considerations. The article is not written in technical “tax speak,” and is intended to be accessible to readers with a non-tax background. It provides an overview of the tax considerations involved in making and holding foreign portfolio investments, a description of the tax treatment of the various participants, and then applies the concepts to three simplified common investment structures. ER -