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The client implemented its Private Credit Funds strategy, including mitigating U.S. taxes for the funds and investors.

The client turned to FTI Consulting to assist with the launch of a new infrastructure fund. By providing immediate tax guidance and support for a “season and sell” strategy, the client was able to minimize U.S. tax leakage for offshore investors in this new offshore infrastructure fund.
The client was able to structure the fund’s loans to be properly “seasoned” prior to offshore investors’ participation, maintaining the independence of its offshore feeder funds from any U.S. trade or business and negating the adverse tax implications of generating effectively connected income on loan originations.


The client implemented its Private Credit Funds strategy, including mitigating U.S. taxes for the funds and investors.

FTI Consulting continues to support the client’s tax function, including the timely implementation and completion of their REIT compliance strategies around all filing deadlines and reporting dates.
FTI Consulting provided analysis, insights and guidance to the client’s tax team to successfully implement their first “season and sell” structure.
Our team analyzed and documented the implications of loan originations and secondary market acquisitions for the fund and investors.
FTI Consulting served as a key project management operative for the tax team throughout their rapid deployment of capital throughout the globe.
The team brought the client leading-edge insights and guidance, such as investment tax credit developments, recently executed international treaty analysis and strategic support to other investment strategies.
FTI Consulting es la empresa líder en el mundo en ayudar a las organizaciones a afrontar el cambio y los procesos de transformación. Liderados por profesionales con amplia experiencia, nuestros expertos responden rápidamente a situaciones dinámicas y complejas, generando un impacto que marca la diferencia.

Descubre cómo nuestro enfoque sectorial genera resultados reales en un mundo cada vez más complejo.

