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The client implemented its Private Credit Funds strategy, including mitigating U.S. taxes for the funds and investors.
Performance Unleashed
Successfully Implementing a Tax Strategy at a Leading Global Investment Firm
Performance Unleashed
Successfully Implementing a Tax Strategy at a Leading Global Investment Firm
Key Contacts
How does a global investment giant launch a new investment structure?
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.
Our Impact
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.
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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.
In crisis and transformation,real-world experience delivers.
Our Role
Designing and deploying an expert-led tax strategy
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.
Real-world experience that delivers.
See why FTI Consulting is the leading global expert firm for organizations facing crisis and transformation.
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