Private Equity and Hedge Funds; A Global Case Study (PHEF)

Gain an expert examination of Private Equity and Hedge Funds in 11 major countries world-wide. In this new Special Report experts provide detailed responses, from their country’s perspective, to the following case study: A group of individuals planning to set up of a Private Equity Fund The group will feature (defined under the Host Country’s income tax law): · Host Country wealthy individual · Foreign wealthy individual · Host Country pension fund and tax exempt entity · Foreign pension fund · Foreign government The fund will be making investments in: business entities formed and operating in the Host Country and business entities formed and operating abroad. The Private Equity Fund will finance its investments only with contributed capital, not with any borrowings. A manager from the Host Country will be making the investment decisions and compensated with a 20% carried interest. See how leading practitioners explain how they would deal with the above case study. Each comprehensive response considers their home country law and outlines: · How the Host Country or foreign business entity would structure a Private Equity Fund to minimise taxation. · The overall preferred structure of a Private Equity Fund (taking into account the above) to minimise taxation. · Basic tax planning for a Hedge Fund, of an investment that generates: host country-source income or foreign-source income. · How the Host Country investment manager will be taxed on income from the carried interest. The solutions and analysis provided give you an authoritative case study, applicable to your own tax planning. Compare and contrast each regime, draw on the differing approaches – benefit from the technical insight. Private Equity and Hedge Funds – A Global Case Study provides you with unparalleled expertise. The leading tax practitioners involved provide local guidance from the following countries: Belgium, Canada, Denmark, France, Germany, Italy, Netherlands, Spain, Switzerland, United Kingdom, United States. The expert panel of contributors consists of: · Howard M. Liebman and Olivier Rousselle, Jones Day, Brussels · Jocelyn Blanchet, Deloitte & Touche LLP, Toronto · Christian Emmeluth, Copenhagen · Stéphane Gelin, Avocat and Johann Roc’h, CMS Bureau Francis Lefebvre, Paris · Dr. Rosemarie Portner, PricewaterhouseCoopers, Düsseldorf · Carlo Galli, Maisto e Associati, Milan and London · Carola van den Bruinhorst and Dennis Langkemper, Loyens & Loeff N.V., Amsterdam · Javier Martín Martín and Montserrat Turrado Alonso, Ernst & Young, Madrid · Walter H. Boss, BLUM Attorneys at Law, Zürich · Nicola Purcell and Amy Manchia, McDermott Will & Emery U.K. LLP, London · Herman B. Bouma, Buchanan Ingersoll & Rooney PC, Washington, D.C.