Tax and structural aspects of private equity investing in the United States : a practical guide for non-U.S. investors and fund managers

In order to acquaint non-US investors and non-US fund managers with the structure and tax consequences of private equity investing in the United States, the article discusses the US tax issues generally raised and the solutions generally implemented in structuring private equity funds to satisfy diffferent, often conflicting, investor constituencies: non-US individuals and institutions, foreign governments, US tax-exempt institutions and US taxable investors.