RT Journal Article
SR Electronic
T1 U.S. Tax Planning Considerations for Investments in Foreign Portfolio Companies
JF The Journal of Private Equity
FD Institutional Investor Journals
SP 76
OP 83
DO 10.3905/jpe.2004.450954
VO 8
IS 1
A1 David M. Neuenhaus
A1 Francis J. Helverson
YR 2004
UL https://pm-research.com/content/8/1/76.abstract
AB 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.