Press Room

February 26, 2015

Schneidman to Speak on Foreign Investment Fund Lending

In a Chief Counsel Advice issued on January 5, 2015, the IRS addressed tax issues with foreign investment fund lending. One of the most important aspects of this CCA is that field agents are encouraged to beef up oversight of these transactions. As such, counsel must be well-equipped to advise clients on how to correctly engage in fund lending.  

At the forefront of this issue is the designation of ‘trade or business’. While, inaccurate consideration of this concept could result in negative tax consequences for foreign investment fund clients, effective use of the safe harbors could result in avoiding the trade or business determination. It is crucial that you understand the red flags that will result in a fund’s actions being considered a trade or business as well as the safe harbor opportunities in order to advise your clients effectively.

Navigating New & Heightened Scrutiny of Foreign Investment Fund Lending Income takes place via webinar on March 17, 2015 from 1:00PM-2:30PM EST. The panel, which includes Len Schneidman, will cover in detail the application of the trade or business designation to foreign investment fund lending as well as effective use of safe harbors, providing tax counsel and advisors with the guidance necessary to survive IRS scrutiny in the context of foreign investment fund lending.

Len Schneidman has over 40 years of experience in international taxation. His work includes counseling clients on structuring and operation of private investment funds, advising high net worth foreign investors on U.S. investments and activities, helping U.S. and non-U.S. corporate clients with tax-efficient structuring of their business operations, and advising clients on the reporting of undisclosed income and/or foreign financial assets from offshore accounts through the IRS Offshore Voluntary Disclosure Program (OVDP) or Streamlined Filing Compliance Procedures, and Report of Foreign Bank and Financial Accounts (FBAR).


March 17, 2015

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